Davis v. United States, No. 16-1840 (8th Cir. 2017)
Annotate this CaseThe district court granted in part petitioner's motion to vacate his drug-related conviction and sentence under 28 U.S.C. 2255, based on ineffective assistance of counsel. The district court ordered the government to reoffer an earlier plea deal. The Eighth Circuit held that the district court clearly erred in finding that petitioner suffered from mental illness that impaired his ability to understand legal advice and make reasoned decisions; the district court erred in finding that counsel should have known that petitioner was not able to understand legal advice or make reasoned decisions; the district court's finding that counsel's communication style did not mesh well with petitioner's difficulties did not provide a basis for ineffective assistance of counsel; the district court did not err in finding counsel deficient in failing to explain the safety-valve exception; and the district court erred in directing the government to reoffer the five-year deal. Accordingly, the court vacated and remanded for the district court to determine whether petitioner was prejudiced by the safety-valve advice.
Court Description: Benton, Author, with Loken and Murphy, Circuit Judges] Habeas Case - Motion to Vacate. Government appeals from the grant of relief on claim asserting ineffective assistance of counsel in failing to provide Davis with information to make an informed decision on a proposed plea agreement and the order to reoffer a five-year plea deal. The district court clearly erred in finding that Davis suffered from mental illness that impaired his ability to understand legal advice and make reasoned decisions, contradicted its finding that Davis was competent to plead guilty and be sentenced, and clearly erred in finding counsel should have known that Davis was not able to understand. The district court's finding that counsel's communication style did not mesh with Davis is insufficient to find ineffective assistance of counsel. The district court did not err in concluding that counsel did not correctly advise Davis about his lack of eligibility for the safety-valve exception to the mandatory minimum sentence, but erred in directing the government to reoffer the five-year deal. The judgment is vacated and remanded to the district court to determine whether Davis was prejudiced by the safety-valve advice.
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