Lockett 诉美利坚合众国案

In May 2013, Antonio Tremain Lockett was indicted for felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1). He pleaded guilty on September 13, 2013, and was sentenced to seventy months of imprisonment on January 9, 2014. Lockett appealed, arguing ineffective assistance of trial counsel for advising him to sign a plea agreement that admitted firearm use during an armed robbery. The Eleventh Circuit suggested he pursue a § 2255 motion. On November 16, 2020, Lockett filed a motion to vacate his sentence under 28 U.S.C. § 2255, later amended to include a claim under Rehaif v. United States. On October 27, 2023, the U.S. District Court for the Northern District of Alabama denied the motion and dismissed the case with prejudice.

The court denied Lockett's § 2255 motion and dismissed the case with prejudice. The ineffective assistance claim was dismissed as time-barred. The Rehaif claim was also dismissed as untimely and, alternatively, on the merits—Lockett's prior nearly five-year prison term provided circumstantial evidence that he knew his felon status. The actual innocence argument failed for lack of new reliable evidence. The court also denied a certificate of appealability.

Whether Lockett received ineffective assistance of counsel when his attorney advised him to sign a plea agreement containing unnecessary factual admissions regarding firearm use during an armed robbery; whether his Rehaif-based claim—that the government failed to prove he knew he was a felon—was timely and meritorious; and whether actual innocence could excuse the untimely filing.

The case illustrates the stringent procedural barriers federal prisoners face when collaterally attacking convictions under § 2255, particularly the one-year statute of limitations. It also demonstrates the limited retroactive effect of Supreme Court decisions like Rehaif and the high threshold for actual innocence claims. Additionally, the case reinforces that prior incarceration serves as strong circumstantial evidence of a defendant's knowledge of felony status, clarifying the application of Rehaif in the Eleventh Circuit.