Larry Junior Copeland, aka La-La v. United States
HabeasCorpus
This Court holds that when a habeas petitioner alleges facts that are outside the courtroom, and if proven, those facts entitle a petitioner to relief, then the district court must permit evidentiary proceedings. Mr. Copeland's allegations involve out-of-court, off-record facts that the government admits show his sentence is three time greater than necessary. Yet, the district court did not conduct an evidentiary hearing. Should the Court of Appeals have granted a certificate of appealability on whether district court abused its discretion?
The district court concluded that "Copeland's Fair Sentencing Act" claims were "not raised on direct appeal. The general rule of procedural default bars Copeland from presenting the claims under § 2255." Congress enacted the First Step Act that expressly provides for the Fair Sentencing Act to apply retroactively. Does the enactment of a retroactively-applicable statute override the procedural default doctrine?
Should the Court of Appeals have granted a certificate of appealability on whether district court abused its discretion?