Ingram v. United States, No. 17-3409 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of a 28 U.S.C. 2255 habeas corpus petition, seeking relief from a mandatory minimum sentence imposed in 2008. The court held that petitioner's 2014 motion was time-barred under section 2255(f)(4). In this case, the issuance of the Commission's 2011 Report was what triggered petitioner's duty to act with diligence, and he failed to do so because he did not file until almost three years later.
Court Description: Chief Judge Smith, Author, with Colloton and Erickson, Circuit Judges] Prisoner Case - Habeas. In claim seeking relief from the mandatory minimum sentence imposed for his 2008 conviction, Ingram asserted in his 2014 motion to vacate under 28 U.S.C. sec. 2255, that it was timely under section 2255(f)(4) after discovery of United States v. Young, 960 F. Supp. 2d 881 (N.D. Iowa 2013) (noting disparity in imposition of section 851 enhancements in the Northern District of Iowa). The district court concluded Ingram's filing was timely under section 2255(f)(4), he acted diligently to discover new facts, and he overcame the procedural default by establishing cause and actual prejudice, but denied the equal protection/selective prosecution claim on the merits. Because Ingram filed his motion three years after the facts underlying the Young decision were released by the Sentencing Commission, Ingram did not exercise due diligence in discovering the facts and filing his motion. Thus, his motion is time- barred.
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