Abu-Aish v. United States

CourtDistrict Court, M.D. Florida
DecidedMarch 31, 2025
Docket8:20-cv-00323
StatusUnknown

This text of Abu-Aish v. United States (Abu-Aish v. United States) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Abu-Aish v. United States, (M.D. Fla. 2025).

Opinion

UMNIIDTEDDL ES TDAISTTERS IDCITS TORFI FCLTO CROIDURAT TAMPA DIVISION

UNITED STATES OF AMERICA

v. CASE NO. 8:16-cr-319-SDM-LSG 8:20-cv-323-SDM-LSG

NEDAL ABU-AISH ____________________________________

ORDER Nedal Abu-Aish moves under 28 U.S.C. § 2255 to vacate his convictions and sentences for conspiracy to possess with intent to distribute a mixture containing a detectable amount of XLR-11 and distribution of a substance containing a detectable amount of XLR-11, for which he is imprisoned for one-hundred-sixty-eight months. A jury found Nedal and his brother, Fayez, guilty of the crimes (Crim. Docs. 122 and 125), and the court of appeals affirmed the convictions and sentences. United States v. Abu-Aish, 758 F. App’x 798 (11th Cir. 2018). At trial, “[t]he evidence presented indicated that Fayez and Nedal manufactured and packaged significant quantities of [XLR-11] in a clandestine lab, sold it out of trash bags on the street, and had suggested to a buyer (an undercover officer) that he should avoid being caught with the product.” Abu-Aish, 758 F. App’x at 800. Nedal asserts that his attorney deficiently performed by failing to advise him that the prosecutor extended a plea offer; that the prosecutor violated Giglio v. United States, 405 U.S. 150 (1972), by knowingly presenting false testimony by a detective; and that a two-level enhancement under the United States Sentencing Guidelines for possessing a firearm was erroneously imposed at sentencing. (Docs. 1 and 2) INEFFECTIVE ASSISTANCE OF COUNSEL STANDARD “‘[T]he cases in which habeas petitioners can properly prevail on the ground of ineffective assistance of counsel are few and far between.’” Waters v. Thomas,

46 F.3d 1506, 1511 (11th Cir. 1995) (quoting Rogers v. Zant, 13 F.3d 384, 386 (11th Cir. 1994)). Strickland v. Washington, 466 U.S. 668, 687 (1984), governs an ineffective assistance of counsel claim and places a heavy burden on a defendant: First, the defendant must show that counsel’s performance was deficient. This requires showing that counsel made errors so serious that counsel was not functioning as the “counsel” guaranteed the defendant by the Sixth Amendment. Second, the defendant must show that the deficient performance prejudiced the defense. This requires showing that counsel’s errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable.

“There is no reason for a court deciding an ineffective assistance claim . . . to address both components of the inquiry if the defendant makes an insufficient showing on one.” Strickland, 466 U.S. at 697. A defendant cannot meet his burden merely by showing that the avenue chosen by counsel proved unsuccessful. White v. Singletary, 972 F.2d 1218, 1220–21 (11th Cir. 1992). “[C]ounsel is strongly presumed to have rendered adequate assistance and made all significant decisions in the exercise of reasonable professional judgment.” Strickland, 466 U.S. at 690. “[A] court deciding an actual ineffectiveness claim must judge the reasonableness of counsel’s challenged conduct on the facts of the particular case, viewed as of the time of counsel’s conduct.” 466 U.S. at 690. Strickland requires that “in light of all the circumstances, the identified acts or omissions were outside the wide range of professionally competent assistance.” 466 U.S. at 690. “[S]trategic choices made after thorough investigation of law and facts relevant to plausible options are virtually unchallengeable; and strategic choices made after less than complete investigation are reasonable precisely

to the extent that reasonable professional judgments support the limitations on investigation.” 466 U.S. at 690–91. “An error by counsel, even if professionally unreasonable, does not warrant setting aside the judgment of a criminal proceeding if the error had no effect on the judgment.” 466 U.S. at 691. To meet this burden, the defendant must show

“a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confidence in the outcome.” 466 U.S. at 694. DISCUSSION Ground One

Nedal asserts that his attorney deficiently performed by failing to advise him that the prosecutor extended a plea offer. (Doc. 1 at 4) He alleges that after trial he first learned that the prosecutor had extended an offer. (Doc. 2 at 2) Attached to his motion is a letter from the prosecutor to his attorney delivered before trial extending an offer. (Doc. 2-1) Nedal alleges that, if his attorney had timely advised him of the

offer, he would have accepted the offer and pleaded guilty. (Doc. 2 at 2) The United States submits with its response an affidavit by Nedal’s attorney, handwritten notes from the attorney’s file, and a copy of the plea agreement. In the plea agreement, the prosecutor agreed to recommend that Nedal receive a sentence within the advisory range under the Sentencing Guidelines, if Nedal pleaded guilty to the conspiracy charge. (Doc. 26-2 at 22–37) In the affidavit, Nedal’s attorney stated that before trial he reviewed the plea agreement with Nedal. (Doc. 13-2 at 5) Nedal’s attorney swore that Nedal rejected the offer and insisted on exercising his

right to a jury trial. (Doc. 13-2 at 5–6) The attorney’s handwritten notes confirms the discussion between the attorney and Nedal about the plea agreement. (Doc. 13-3) Because resolving this dispute of material fact requires a credibility determination, an earlier order granted Nedal an evidentiary hearing. (Doc. 29)

At the evidentiary hearing, Nedal did not testify. Nedal’s attorney testified that Nedal denied that he knew that XLR-11 was a controlled substance. (Doc. 45 at 97–98, 110) Nedal’s attorney testified that Nedal showed no interest in pleading guilty because he believed that he did not commit a crime. (Doc. 45 at 99) Nedal’s attorney nonetheless requested a plea agreement from the prosecutor. (Doc. 45

at 99) On October 24, 2016, immediately after receiving the plea agreement, Nedal’s attorney responded to the prosecutor by e-mail (Doc. 42-3 at 18): “I received the plea agreement, but as of now [Nedal] intends to proceed to trial.” Nedal’s attorney acknowledged that he had not spoken with Nedal about the plea agreement before sending that response. (Doc. 45 at 135)

On October 27, 2016, Nedal’s attorney met with Nedal to discuss the terms of the agreement. (Doc. 45 at 100–02) During the meeting, Nedal’s attorney gave to Nedal a copy of the agreement and asked Nedal’s brother, Fayez, to assist as an interpreter. (Doc. 45 at 101, 141–42) Nedal’s attorney described the conversation about the terms of the agreement as follows (Doc. 45 at 102–03): [Prosecutor:] What specifically do you recall being discussed with Nedal Abu-Aish about the plea agreement that the United States had tendered for his consideration?

[Nedal’s attorney:] So, we discussed what the offer was, what he would be pleading to. We discussed possible penalties of that. We discussed, and I did an actual calculation of what I believed his guideline range would be, if he accepted the plea, which included acceptance.

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