Aceituno v. United States

132 F.4th 563
CourtCourt of Appeals for the First Circuit
DecidedMarch 27, 2025
Docket24-1343
StatusPublished

This text of 132 F.4th 563 (Aceituno v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aceituno v. United States, 132 F.4th 563 (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

No. 24-1343

WALTER ACEITUNO,

Petitioner, Appellee,

v.

UNITED STATES,

Respondent, Appellant.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND

[Hon. John J. McConnell, Jr., U.S. District Judge]

Before

Aframe, Lynch, and Howard, Circuit Judges.

Katherine C. Essington for appellee.

Lauren S. Zurier, Assistant United States Attorney, with whom Zachary A. Cunha, United States Attorney, was on brief, for appellant.

March 27, 2025 LYNCH, Circuit Judge. The United States appeals from

the grant of the petition for a writ of error coram nobis of Walter

Aceituno, a citizen of Guatemala. Aceituno's petition alleges

that he is entitled to this "hen's-teeth rare" writ, United States

v. George, 676 F.3d 249, 254 (1st Cir. 2012), because his

attorneys, before he pled guilty in 2014 to drug-trafficking

charges, had informed him he would be deported but did not go

further to inform him that his guilty plea would result in a

permanent ban on reentering the United States. Aceituno's petition

does not contest that he was guilty of drug trafficking, that

Immigration and Custom's Enforcement (ICE) informed him prior to

his departure in 2014 that he was permanently barred from reentry,

or that he illegally reentered in 2019. Rather, his coram nobis

argument is that he should be permitted to withdraw his 2014

criminal plea and vacate his criminal conviction based on the

allegedly ineffective assistance of his attorney.

In granting the writ and allowing withdrawal of the plea,

the district court committed errors of law and a clear error of

fact and ventured beyond the bounds of its discretion.

I.

Aceituno is a Guatemalan citizen who became a lawful

permanent resident of the United States in 1989 but lost that

status in 2014. He ran a barber shop in Pawtucket, Rhode Island.

On April 18, 2013, Aceituno drove one of the barbers who rented

- 2 - space in his shop, Geronimo Ramos, to a meeting in Warwick, Rhode

Island. At the meeting, Aceituno and Ramos "discussed the purchase

of two kilograms of cocaine at $28,000 per kilogram," as well as

the future purchase of three additional kilograms. During these

conversations, Aceituno inquired about the cocaine's purity. In

fact, they were meeting with an undercover Drug Enforcement Agency

(DEA) agent and a cooperating witness. When the discussion

concluded, Aceituno and Ramos left the restaurant and travelled to

Aceituno's barber shop to obtain the purchase money. After an

hour passed without contact from the two men, the cooperating

witness called Ramos to see what was causing the delay. Ramos

informed the cooperating witness that he only had enough money for

one kilogram of cocaine and that he was trying unsuccessfully to

reach a friend who had money for the second kilogram. The

cooperating witness told Ramos to return with the money he had.

Ramos and Aceituno did so, meeting the cooperating witness and

undercover DEA agent in the parking lot of the Warwick Mall. At

that second meeting, Ramos showed the cooperating witness

approximately $28,000 in a plastic bag. The cooperating witness

then told Aceituno and Ramos that they would all go to Aceituno's

barber shop in Pawtucket to make the exchange, at which time

Aceituno and Ramos began to drive away. As they did, other members

of the investigation team approached the Mercury Mountaineer

Aceituno was driving and Aceituno attempted to drive away and flee

- 3 - the scene, but he was stopped a short distance away. Aceituno and

Ramos were both arrested, and Aceituno was charged with conspiracy

to possess with intent to distribute cocaine and attempted

possession of cocaine with intent to distribute.

Aceituno retained two lawyers in relation to his arrest:

Thomas F. Connors, a criminal defense attorney, and Robert D. Watt,

an immigration attorney. Attorney Watt had been helping the family

of Aceituno's common-law wife with immigration matters since the

1980s and is a skilled immigration attorney. On January 7, 2014,

after consulting with both his attorneys, Aceituno pled guilty,

pursuant to an agreement, to conspiracy to possess with intent to

distribute cocaine and attempt to possess with intent to distribute

cocaine. As we describe below, both attorneys Connors and Watt

provided Aceituno with advice before he entered his plea that he

would certainly be deported after entering the plea.

Under the plea agreement, the government agreed to

recommend a sentence at the low end of the guidelines range and a

three-level reduction in Aceituno's offense level for the purpose

of calculating that range, reducing the guidelines range imposed

from 63-78 months of incarceration to 46-57 months. See U.S.S.G.

ch. 5 pt. A. The agreement also stated that "Defendant recognizes

that pleading guilty may have consequences with respect to his

immigration status if he is not a citizen of the United States"

and that "because Defendant is pleading guilty to conspiracy to

- 4 - possess with intent to distribute cocaine and attempted possession

with intent to distribute cocaine, removal is presumptively

mandatory." The agreement further stated that "Defendant

understands that no one, including his attorney or the district

court, can predict to a certainty the effects of his conviction on

his immigration status." In signing the plea agreement, Aceituno

"nevertheless affirm[ed] that he want[ed] to plead guilty

regardless of any immigration consequences that his plea may

entail."

At his change-of-plea hearing, Aceituno stated that he

understood that pleading guilty made it "quite likely and probable"

that he would be deported after serving any period of

incarceration. Aceituno never asked his lawyers whether he would

be able to return to the United States after being deported, nor

did they otherwise discuss the issue. Aceituno affirmed that he

was "completely satisfied" with the representation he had received

from his lawyers.

Attorneys Connors and Watt were both present for

Aceituno's sentencing hearing on March 25, 2014. During that

hearing, attorney Connors acknowledged that Aceituno would be

deported as a result of his conviction and contended that this

justified imposition of a below-guidelines sentence. Aceituno was

sentenced to time served (approximately eleven months) and three

- 5 - years of supervised release, despite the guidelines range of 46-

57 months of incarceration.

Aceituno was taken into custody by Immigration and

Customs Enforcement (ICE) shortly after sentencing and, again

represented by attorney Watt, conceded before an Immigration Judge

that his criminal conviction made him removable. Aceituno sought

to avoid removal by arguing that he was eligible for withholding

of removal and protection under the Convention Against Torture

(CAT). The Immigration Judge found that Aceituno did not satisfy

the relevant legal criteria and ordered him removed to Guatemala.

The Board of Immigration Appeals affirmed the judgment and Aceituno

was removed to Guatemala in January 2015.

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