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Keywords

defendantappealpleamotionhabeas corpusguilty plea
defendantappealpleamotionhabeas corpusguilty plea

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Copelin v. U.S., Not Reported in F.Supp.2d, 2006 WL 2644965

Facts

Darrius Copelin, along with two co-defendants, pled guilty to bank robbery and related charges in 2003 and was sentenced to 121 months in prison. After his appeal was dismissed as untimely, he filed a motion to vacate his sentence, which was denied by the district court. Copelin later filed a petition for writ of habeas corpus, arguing that he was not informed of his right to appeal and that he received ineffective assistance of counsel.

On May 29, 2003 petitioner and two co-defendants, Andre Cassimere and Calvin Scott, pled guilty to bank robbery and other related charges in the United States District Court for the Eastern District of Louisiana.

Issue

Whether Darrius Copelin's claims regarding the validity of his guilty plea and the alleged ineffective assistance of counsel could be properly raised in a § 2241 habeas corpus petition.

The initial inquiry is whether or not petitioner's claim may be properly raised in a § 2241 habeas corpus petition.

Rule

A federal prisoner may use § 2241 to challenge the legality of their convictions or sentences only if they satisfy the § 2255 'savings clause', which requires showing that the § 2255 remedy is inadequate or ineffective.

The 'savings clause' provides that a federal convict may file a writ of habeas corpus pursuant to § 2241 if the § 2255 motion's remedy is 'inadequate or ineffective to test the legality of his detention.'

Analysis

The court analyzed whether Copelin's claims could be raised under § 2241 and determined that they were more appropriately addressed through a § 2255 motion. The court noted that Copelin did not demonstrate that his claims were based on a retroactively applicable Supreme Court decision or that they were foreclosed by circuit law at the time they should have been raised.

Such claims are more properly raised in a Motion to Vacate filed pursuant to § 2255. Therefore petitioner may bring this habeas action only if he can demonstrate that § 2255's remedy is 'inadequate or ineffective to test the legality of his detention.'

Conclusion

The court recommended that Copelin's petition for writ of habeas corpus be denied and dismissed with prejudice, as he failed to meet the necessary criteria to proceed under the 'savings clause' of § 2255.

Accordingly, IT IS RECOMMENDED THAT petitioner's Petition for Writ of Habeas Corpus be DENIED and DISMISSED WITH PREJUDICE.

Who won?

The Federal Bureau of Prisons prevailed in the case as the court recommended the denial of Copelin's habeas corpus petition, finding that he did not meet the requirements to challenge his conviction under § 2241.

The court notes that the plea agreement signed by the defendant waived any right to appeal, and that the Court accepted the guilty plea only conditionally prior to the review of the pre-sentence report and sentencing.

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