Daniels v. United States

Summary

The Supreme Court held that, as a general rule, a federal prisoner may not use a § 2255 motion to collaterally attack the validity of prior convictions used to enhance his sentence under the Armed Career Criminal Act once those convictions are no longer open to direct or collateral attack in their own right; the presumption of validity that attaches to an unchallenged predicate becomes conclusive, and the Gideon right-to-counsel exception survives only for claims generally raised at the sentencing proceeding. Extending its earlier sentencing-forum ruling, the Court reasoned that district courts lack access to decades-old state records — Daniels's own plea transcripts were missing — and that states retain continuing interests in their judgments through civil disabilities and recidivist statutes, so permitting § 2255 attacks would sanction an end run around statutes of limitations and procedural default. Because Daniels conceded he had not pursued the remedies available against his 1978 and 1981 robbery convictions, the Court affirmed the Ninth Circuit's judgment sustaining the denial of his § 2255 motion, expressly reserving whether § 2255 might be available in rare cases where no channel of review existed through no fault of the defendant. Justice Scalia concurred in part but refused to join the rare-circumstances reservation on textual grounds; Justice Souter, joined by Justice Stevens and Justice Ginsburg, dissented as lacking any basis in § 2255's text or congressional intention; Justice Breyer dissented, urging reconsideration of the earlier sentencing-forum ruling itself.