Jean-Daniel Perkins v. USA, No. 20-14781 (11th Cir. 2023)
Annotate this Case
After perpetrating elaborate bank and credit card fraud, Petitioner “embarked upon a new scheme . . . to ensnarl the proceedings against him” through obstructionist and disruptive behaviors “so that he might avoid trial altogether.” His scheme, however, did not end at trial or even when the jury issued its guilty verdict. Rather, it continued through sentencing. Now, on a motion to vacate his sentence pursuant to 28 U.S.C. Section 2255, Petitioner advances two claims: a substantive competency due process claim, contending that he was not competent at the time of sentencing, and an ineffective-assistance-of-counsel claim. The district court denied his Section 2255 motion.
The Eleventh Circuit affirmed. The court explained that Petitioner’s substantive due process rights were not violated when the district court denied his motion for a competency hearing. Nor did Petitioner receive constitutionally deficient performance from court-appointed counsel when they failed to request his medical records or request a mental health evaluation. Even if such failures constituted deficient performance, Petitioner has not demonstrated that he was prejudiced as a result. Thus, the district court did not err in denying Perkins’s Section 2255 motion.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.