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United States v. Sheffield

2026-08-27

Summary

Holding. The court denied Sheffield's § 2255 motion to vacate his sentence because he expressly waived his right to bring collateral attacks in his plea agreement, and his claim did not fall within the limited exceptions for newly discovered evidence or ineffective assistance of counsel.

Robert Sheffield pleaded guilty to conspiracy to commit Hobbs Act robbery and to a firearms charge under 18 U.S.C. § 924(c), in which he admitted that a Hobbs Act robbery served as his predicate crime of violence. As part of his plea agreement, Sheffield expressly waived his right to file collateral challenges to his conviction and sentence, except for claims based on newly discovered evidence or ineffective assistance of counsel. Approximately eleven months after sentencing, Sheffield filed a motion under 28 U.S.C. § 2255 arguing that neither conspiracy to commit Hobbs Act robbery nor attempted robbery can qualify as a predicate offense for a § 924(c) charge.

The court held that Sheffield's collateral attack was barred by the express waiver contained in his plea agreement. The court found that Sheffield's waiver was knowing, intelligent, and voluntary based on his confirmed understanding at the plea hearing and the colloquy conducted by the court. Because Sheffield's argument did not fall within the two exceptions to the waiver—newly discovered evidence or ineffective assistance of counsel—the court declined to consider the merits of his predicate-offense claim. The court also noted that even absent the waiver, Sheffield's motion would have been procedurally defaulted because he failed to raise the issue on direct appeal.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Enforceability of collateral-attack waivers in plea agreements
  • Whether Hobbs Act conspiracy or attempted robbery qualifies as a predicate 'crime of violence' under 18 U.S.C. § 924(c)
  • Scope of exceptions to plea-agreement waivers
  • Procedural default of claims not raised on direct appeal

Procedural posture

Sheffield filed a pro se motion under 28 U.S.C. § 2255 to vacate his sentence approximately eleven months after the district court entered final judgment, and the government opposed the motion.

Authorities cited

Opinion

majority opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

v.

ROBERT SHEFFIELD [13], Case No. 23-cr-137-13 (CRC)

Defendant.

OPINION AND ORDER

Defendant Robert Sheffield has filed a pro se motion to vacate his sentence under 28

U.S.C. § 2255. He submits that his conviction for conspiracy to commit Hobbs Act robbery

cannot serve as the predicate “crime of violence” for his conviction under 18 U.S.C. § 924(c).

But Mr. Sheffield expressly waived this type of collateral challenge in his plea agreement, so the

Court must deny his § 2255 motion.

I. Background

The Court draws the following facts from the statement of offense that Sheffield accepted

as part of his plea agreement. See Statement of Offense in Support of Guilty Plea (“Statement of

Offense”) at 7.

A. Factual Background

From November 2022 to August 2023, Sheffield conspired with others to rob commercial

establishments along the East Coast, mostly small South Asian jewelry stores. Id. at 3. They

targeted stores that sold gold of a certain purity because of its higher resale value. Id. In

November 2022, Sheffield and six others robbed a jewelry store in Harrisburg, Pennsylvania,

ransacking the store while holding its employees at gunpoint. Id. at 3–4. They left the store with

approximately $1 million in gold jewelry. Id. at 4. A few months later, Sheffield and his coconspirators attempted to rob another jewelry store in Falls Church, Virginia. Id. When a store

employee brandished a firearm, Sheffield shot at the store’s owner with a 40-caliber handgun

before fleeing the scene. Id. at 4–5.

B. Procedural History

On August 30, 2023, Sheffield was arrested in the District of Columbia. Id. at 5. The

grand jury charged him with conspiracy to commit Hobbs Act robbery in violation of 18 U.S.C.

§ 1951; Hobbs Act robbery in violation of 18 U.S.C. § 1951; using, carrying, brandishing, and

possessing a firearm in furtherance of a crime of violence and aiding and abetting in violation of

18 U.S.C. § 924(c); and being a felon in possession of a firearm in violation of 18 U.S.C.

§ 922(g). See Second Superseding Indictment at 2–6, 10–11, 20–21. On February 20, 2025,

Sheffield pleaded guilty to one count of conspiracy to commit Hobbs Act robbery and one count

under 18 U.S.C. § 924(c). See Statement of Offense at 1–2; Plea Agreement at 1. For the 18

U.S.C. § 924(c) count, Sheffield admitted that he (1) “committed a crime of violence—here,

Interference with Interstate Commerce by Robbery, in violation of 18 U.S.C. § 1951”;

(2) “knowingly possessed a firearm”; and (3) possessed the firearm “during and in relation to, or

in furtherance of, [his] crime of violence.” Statement of Offense at 2; see id. at 7.

As part of his plea agreement, Sheffield waived almost all of his rights to challenge his

conviction and sentence, including his ability to raise a collateral attack:

[Sheffield] waives any right to challenge the conviction entered or sentence

imposed under [the plea agreement] or otherwise attempt to modify or change the

sentence or the manner in which it was determined in any collateral attack,

including, but not limited to, a motion brought under 28 U.S.C. § 2255 or Federal

Rule of Civil Procedure 60(b), except to the extent such a motion is based on newly

discovered evidence or on a claim that [Sheffield] received ineffective assistance

of counsel.

Plea Agreement at 8. At his plea hearing, Sheffield confirmed that he reviewed and understood

the terms of his plea agreement. See Plea Hr’g Rough Tr. at 14–15.

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On July 2, 2025, the Court sentenced Sheffield to consecutive terms of 40 months for the

conspiracy count and 60 months for the 18 U.S.C. § 924(c) count, for a total of 108 months in

prison. See Judgment at 1, 3. Judgment was entered on July 10, 2025. Id. at 1. Sheffield did

not appeal his conviction or sentence. See Motion Under 28 U.S.C. § 2255 to Vacate, Set Aside,

or Correct Sentence by a Person in Federal Custody (“Def.’s Mot.”) at 2.

Approximately eleven months after the Court issued final judgment, on June 9, 2026,

Sheffield filed a pro se motion to vacate, set aside, or correct his sentence under 28 U.S.C.

§ 2255. See id. at 1, 13. The government opposed his motion and filed its opposition on July 29,

2026. See United States’ Opp’n to Def.’s Mot. to Vacate, Set Aside, or Correct Sentence. The

motion is fully briefed and ripe for adjudication. For the following reasons, the Court will deny

the motion.

II. Legal Standards

A defendant in federal custody “may move the court which imposed [his] sentence to

vacate, set aside or correct the sentence” on the “ground that the sentence was imposed in

violation of the Constitution or laws of the United States,” that the sentencing court “was without

jurisdiction,” that the sentence imposed “was in excess of the maximum authorized by law,” or

that the sentence “is otherwise subject to collateral attack.” 28 U.S.C. § 2255(a). “Because of the

premium placed on the finality of judgments, there are limited circumstances under which a

court should grant a Section 2255 motion.” Bedewi v. United States, 583 F. Supp. 2d 72, 76

(D.D.C. 2008) (citation omitted). The defendant bears the burden of demonstrating that he is

entitled to relief under 28 U.S.C. § 2255, where the burden of proof is a preponderance of the

evidence. United States v. Pollard, 602 F. Supp. 2d 165, 168 (D.D.C. 2009).

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III. Analysis

Sheffield argues that his § 924(c) conviction must be set aside because neither conspiracy

to commit Hobbs Act robbery nor attempted Hobbs Act robbery “can serve as predicate offenses

for an additional 18 U.S.C. [§] 924(c)(1)(A) charge.” Def.’s Mot. at 4. In his view, neither

offense “contain[s] the necessary elements of use, attempted use, or threatened use of physical

force to serve as predicate offenses for an additional [§] 924(c)(1)(A) charge.” Id. He further

explains that he did not raise this claim on direct appeal because his counsel “refused” to raise it.

Id. at 4, 10. However, because Sheffield waived this collateral attack as part of his plea

agreement, he cannot now pursue this argument.

This is not the first time a defendant in this case has raised a collateral challenge to his

§ 924(c) conviction after pleading guilty. In April 2025, Defendant Andrew Smith filed a nearly

identical § 2255 motion, asserting that his § 924(c) conviction “must be set aside because the

‘crime of violence’ statutory element cannot be satisfied by Hobbs Act conspiracy.” Op. &

Order (“Smith Op. & Order”) at 4, United States v. Smith, No. 23-cr-137-12 (CRC) (D.D.C.

Aug. 5, 2025). The Court concluded that Mr. Smith’s § 2255 challenge was “barred” by the

terms of his plea agreement, which “waived ‘any right to challenge the conviction entered or

sentence imposed . . . in any collateral attack, including, but not limited to, a motion brought

under 28 U.S.C. § 2255.” Id. (quoting Plea Agreement at 8, United States v. Smith, No. 23-cr137-12 (CRC) (D.D.C. May 29, 2024)). Regardless of whether Smith’s claims were

constitutional or statutory, the Court explained that he had waived his right to challenge his

conviction in exchange for the government’s dismissal of the other felony charges against him.

Id. at 5. Indeed, other courts have recognized that “a waiver is enforceable under nearly the

exact circumstances presented” by Smith’s motion. Id. (citing Cook v. United States, 84 F.4th

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118, 121, 124 (2d Cir. 2023); Portis v. United States, 33 F.4th 331, 335 (6th Cir. 2022))

(discussing two cases concerning conspiracy to commit Hobbs Act robbery as a predicate

offense where the court upheld the enforceability of the collateral-attack waiver despite a

subsequent legal development in United States v. Davis, 588 U.S. 445, 470 (2019), in which the

Supreme Court limited what qualifies as a predicate offense).

For the reasons articulated in Smith, Sheffield’s § 2255 motion is likewise barred by the

express terms of his plea agreement. In his plea agreement, Sheffield waived his right “to

challenge the conviction entered or sentence imposed,” including by “a motion brought under 28

U.S.C. § 2255.” Plea Agreement at 8. Only two exceptions are set out in that waiver: (1) a

“motion based on newly discovered evidence”; and (2) a motion based on a claim that he

“received ineffective assistance of counsel.” Id. Neither exception is applicable here, however,

because Sheffield’s only claim is that neither conspiracy to commit Hobbs Act robbery nor

attempted Hobbs Act robbery can serve as a predicate offense for a § 924(c) charge. See Def.’s

Mot. at 4. And nothing in the record suggests that Sheffield’s waiver was not “knowing,

intelligent and voluntary.” Khadr v. United States, 67 F.4th 413, 419 (D.C. Cir. 2023); see Plea

Hr’g Rough Tr. at 6 (demonstrating that the Court explicitly asked Sheffield whether he

understood that “by pleading guilty, [he] would be giving up most of [his] appellate rights,” to

which Sheffield responded, “Yes, sir”); Plea Hr’g Rough Tr. at 16 (concluding that “[t]he Court

is satisfied that Mr. Sheffield . . . understands . . . the consequences of his plea” and “that the

plea of guilty is knowing and voluntary” after engaging in a colloquy with Sheffield).

Accordingly, the Court must give effect to the waiver and deny his motion. 1

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As the Court noted in Mr. Smith’s case, “[e]ven if [the defendant] had not waived his collateral challenge, it fails for an independent reason,” which is that his motion was “procedurally defaulted” because “Smith never sought direct review of his claim.” Smith Op. &

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When a district court enters a final order resolving a petition under 28 U.S.C. § 2255 that

is adverse to the applicant, it must either issue or deny a certificate of appealability. See Rules

Governing Section 2255 Proc. for the U.S. Dist. Cts., Rule 11(a). By statute, “[a] certificate of

appealability may issue . . . only if the applicant has made a substantial showing of the denial of

a constitutional right.” 28 U.S.C. § 2253(c)(2). Sheffield has not made such a showing here, so

the Court declines to issue a certificate of appealability.

IV. Conclusion

For the foregoing reasons, it is hereby

ORDERED that Defendant’s [394] Motion to Vacate is DENIED. It is further

ORDERED that the Clerk of the Court shall notify Defendant of this Order. It is further

ORDERED that the Clerk of the Court shall close Civil Case No. 26-2094 (CRC).

SO ORDERED.

CHRISTOPHER R. COOPER

United States District Judge

Date: August 27, 2026

Order at 6 n.2 (citing United States v. Hughes, 514 F.3d 15, 17 (D.C. Cir. 2008)). Here, too, Sheffield never sought direct review of his claim, see Def.’s Mot. at 2, so his collateral-challenge claim also fails for that reason. Moreover, while the Court need not reach the merits of Sheffield’s argument, as in Smith, see Smith Op. & Order at 6 n.2, the predicate crime for the § 924(c) conviction appears to be the crime of committing the Hobbs Act robbery rather than Hobbs Act conspiracy, see Plea Hr’g Rough Tr. at 7 (stating explicitly that “the elements are, first, that the defendant committed a crime of violence, which is the Hobbs Act robbery referenced in Count 1” (emphasis added)).

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