Commonwealth v. James Kiptanui.

CourtMassachusetts Appeals Court
DecidedMarch 11, 2024
Docket22-P-1054
StatusUnpublished

This text of Commonwealth v. James Kiptanui. (Commonwealth v. James Kiptanui.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. James Kiptanui., (Mass. Ct. App. 2024).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

22-P-1054

COMMONWEALTH

vs.

JAMES KIPTANUI.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The defendant, James Kiptanui, appeals from the denial of

his motion to withdraw his guilty pleas based on ineffective

assistance of plea counsel under art. 12 of the Massachusetts

Declaration of Rights and Commonwealth v. Lavrinenko, 473 Mass.

42 (2015). We vacate the orders denying his motion and remand

for an evidentiary hearing.

Background. The defendant, a refugee from Kenya, pleaded

guilty in 2018 to assault and battery on a family or household

member, in violation of G. L. c. 265, § 13M (a), and assault and

battery by means of a dangerous weapon (a knife), in violation

of G. L. c. 265, § 15A (b). Two years later, represented by new

counsel, he filed a motion to withdraw his guilty pleas on the

ground that plea counsel failed to inquire into his immigration

status and, as a result, failed to advise him that the convictions would result in presumptively mandatory deportation

proceedings and deprive him of the ability to obtain

discretionary relief from removal. The defendant supported his

motion with his own affidavit and that of plea counsel. The

defendant stated that he did not remember plea counsel asking

him about his immigration status, and that plea counsel did not

provide specific advice on how the pleas would affect his

refugee status, but that counsel did warn him in general terms

that his pleas might have adverse immigration consequences.

Plea counsel averred that he had no specific memory of what he

told the defendant. Although his standard practice was to ask

clients about their citizenship, he was unaware that the

defendant was not a citizen, he did not remember if he asked the

defendant about his citizenship, and he did not remember the

defendant telling him he was not a citizen.

The same judge who had taken the defendant's guilty pleas

held a nonevidentiary hearing on the defendant's motion. At the

hearing it came to light that a few months before the defendant

pleaded guilty, the Department of Homeland Security (DHS) had

initiated deportation proceedings against him based on a 2012

Ohio conviction for grand theft of a motor vehicle. The

defendant was not in DHS custody at the time of his guilty

pleas. Indeed, it appears that he was being held in the house

of correction on this matter, his bail having been revoked for

2 failing to appear at the originally scheduled trial date, when

he was served with the notice to appear for removal proceedings.

The judge denied the motion, finding that the defendant had

failed to demonstrate that he was unaware of the potential

immigration consequences of his guilty pleas. The judge did not

credit the defendant's assertion that he did not understand the

mandatory consequences of his guilty pleas, inferring that he

would have known the consequences based on the already pending

removal proceedings against him. The judge noted that she had

given the defendant the required statutory immigration warnings

and that the defendant admitted that counsel had informed him

that the guilty pleas might have immigration consequences;

however, she did not credit the defendant's statement that there

was no further discussion of the consequences. The defendant

timely filed a notice of appeal.

After the defendant had filed his appellate brief, the

Commonwealth, with the defendant's assent, obtained a stay of

the appeal to permit the parties "to resolve the matter in the

District Court." The parties then filed a joint motion to

reconsider, asking the judge to "[m]ake specific findings as to

how plea counsel advised the defendant," whether this advice was

constitutionally adequate, and, if not, whether the defendant

was prejudiced.

3 The judge held a second nonevidentiary hearing. At the

hearing, the defendant, through counsel, conceded that he would

have difficulty proving prejudice arising from plea counsel's

failure to advise him about deportation, given that the

defendant was already in deportation proceedings based on the

Ohio conviction. The defendant continued to press his claim

that plea counsel was ineffective for failing to advise him that

pleading guilty to a crime of violence would prevent him from

obtaining discretionary relief from removal and that this

failure resulted in prejudice. The judge again found that the

defendant had been advised of immigration consequences in

general terms, but added that plea counsel failed to advise the

defendant about how the pleas would affect his immigration

status because the defendant failed to advise counsel about the

pending deportation proceedings. Again the judge denied the

motion, finding that it foundered on the defendant's failure to

prove the first prong of the Commonwealth v. Saferian, 366 Mass.

89, 96 (1974), standard. This appeal followed.

Discussion. A motion to withdraw a guilty plea is treated

as a motion for a new trial. See Lavrinenko, 473 Mass. at 47.

"We examine the granting or denial of a new trial motion 'only

to determine whether there has been a significant error of law

or other abuse of discretion.'" Commonwealth v. Lys, 481 Mass.

1, 4 (2018), quoting Lavrinenko, supra.

4 "[E]ven where, as here, a refugee is inadmissible and

deportable, the refugee may still seek an adjustment of status

from refugee to lawful permanent resident by applying for a

waiver of inadmissibility." Lavrinenko, 473 Mass. at 49-50,

citing 8 U.S.C. § 1159(c) (2012). To competently advise the

defendant about the immigration consequences of his guilty

pleas, it was essential for plea counsel to understand the

defendant's status. See Lavrinenko, supra at 53-54.

"Therefore, the failure of a criminal defense attorney to make a

reasonable inquiry of the client regarding his or her

citizenship and immigration status is sufficient to satisfy the

deficient performance prong of the ineffective assistance

analysis." Id. at 53.

The defendant argues that he presented a substantial

showing that plea counsel did not conduct sufficient inquiry

into his immigration status or provide the advice required by

Lavrinenko and asks that we remand for an evidentiary hearing.

A judge must hold an evidentiary hearing on a new trial motion

if the defendant presents a "substantial issue," an inquiry that

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Related

Commonwealth v. Saferian
315 N.E.2d 878 (Massachusetts Supreme Judicial Court, 1974)
Commonwealth v. Vaughn
30 N.E.3d 76 (Massachusetts Supreme Judicial Court, 2015)
Commonwealth v. Lavrinenko
38 N.E.3d 278 (Massachusetts Supreme Judicial Court, 2015)
Commonwealth v. Lys
110 N.E.3d 1201 (Massachusetts Supreme Judicial Court, 2018)
Commonwealth v. Va Meng Joe
682 N.E.2d 586 (Massachusetts Supreme Judicial Court, 1997)
Commonwealth v. Denis
814 N.E.2d 1080 (Massachusetts Supreme Judicial Court, 2004)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)

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Commonwealth v. James Kiptanui., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-james-kiptanui-massappct-2024.