United States v. Reves, No. 13-15845 (9th Cir. 2014)
Annotate this CaseDefendants Reves and Bedford appealed the denial of their motions to vacate their sentence. Defendants' convictions stemmed from their involvement in a scheme in ensuring that Sunlaw Energy received a bid to construct a plant in the Port of Stockton instead of Sunlaw's competitor. The court concluded that the district court did not have jurisdiction to consider Bedford's 18 U.S.C. 2255 motion where Bedford was not actually in custody at the time he filed his motion. Therefore, the court reversed the denial of Bedford's section 2255 motion to vacate his sentence and remanded with instructions to dismiss the motion for lack of jurisdiction. The court concluded that the district court properly concluded that Reves's section 2255 motion was untimely and that he did not qualify for the actual innocence or equitable tolling exceptions. Further, Reves expressly waived his right to collaterally attack his conviction or sentence through a section 2255 motion in his plea agreement and during his change of plea colloquy. Accordingly, the court affirmed the judgment as to Reves.
Court Description: Habeas Corpus. The panel affirmed in part, and reversed and remanded in part, in a consolidated appeal arising from the district court’s judgments denying as untimely J. Tyler Reves’s and Lynn G. Bedford’s motions to vacate their sentences under 28 U.S.C. § 2255. The panel held that the district court did not have jurisdiction to consider Bedford’s § 2255 motion because Bedford, whose sentence of probation expired the day before his motion was filed, was not “in custody” at the time he filed his motion, as required by § 2255(a). The panel held that the Federal Rules of Civil Procedure did not operate to extend Bedford’s sentence, which ended on a Sunday, by one more day. The panel explained that the jurisdictional requirement that a § 2255 motion is only available to a prisoner in custody is a condition that either exists or does not exist, rather than a statute of limitations or other deadline for filing, as contemplated by the Federal Rules. The panel therefore reversed the district court’s denial of Bedford’s motion as untimely, and remanded with directions to dismiss the motion for lack of jurisdiction. The panel held that the district court was correct that Reves’s motion was untimely and that he does not qualify for the actual innocence or equitable tolling exceptions. The panel wrote that judicial opinions and exonerations of others do not affect the factual or legal basis for Reves’s conviction pursuant to his plea agreement. The panel also found that Reves expressly waived his right to collaterally attack his conviction or sentence through a § 2255 motion in his plea agreement and during his change of plea colloquy; and concluded that the waiver is enforceable.
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