Cruz-Polanco v. United States

CourtDistrict Court, S.D. New York
DecidedJanuary 22, 2024
Docket1:22-cv-08935
StatusUnknown

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

Bluebook
Cruz-Polanco v. United States, (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA 21-CR-709 (JPO) -v- 22-CV-8935 (JPO) JOHAN CRUZ-POLANCO, ORDER Defendant.

J. PAUL OETKEN, District Judge: Presently before the Court is Defendant Johan Cruz-Polanco’s motion under 28 U.S.C. § 2255, to vacate, set aside, or correct his sentence. Defendant pleaded guilty to one count of conspiring to distribute and to possess with intent to distribute 400 grams and more of mixtures and substances containing a detectable amount of fentanyl, in violation of 21 U.S.C. §§ 841(b)(1)(A) and 846. On January 12, 2022, Judge John F. Keenan accepted Defendant’s guilty plea as knowing and voluntary. On May 26, 2022, Judge Loretta A. Preska sentenced Defendant to 72 months’ imprisonment. Proceeding pro se, Defendant moves to vacate his sentence on grounds of ineffective assistance of counsel. I. Legal Standards Under 28 U.S.C. § 2255, an individual convicted of federal crimes may petition a court to vacate, set aside, or correct his sentence. “[C]ollateral attack on a final judgment in a criminal case is generally available under § 2255 only for a constitutional error, a lack of jurisdiction in the sentencing court, or an error of law or fact that constitutes a fundamental defect which inherently results in a complete miscarriage of justice.” United States v. Bokun, 73 F.3d 8, 12 (2d Cir. 1995) (internal quotation marks omitted). “Because collateral challenges are in tension with society’s strong interest in the finality of criminal convictions, the courts have established rules that make it more difficult for a defendant to upset a conviction by collateral, as opposed to direct, attack.” Yick Man Mui v. United States, 614 F.3d 50, 53 (2d Cir. 2010). Where a petitioner is pro se, as is the case here, the petition is held to “less stringent standards than [those] drafted by lawyers,” and a court must construe the petitioner’s submissions “liberally and

interpret them to raise the strongest arguments that they suggest.” Santiago v. United States, 187 F. Supp. 3d 387, 388 (S.D.N.Y. 2016) (internal quotation marks omitted). However, pro se litigants are “not exempt from compliance with the relevant rules of procedural and substantive law.” Carrasco v. United States, 190 F. Supp. 3d 351, 352 (S.D.N.Y. 2016) (internal quotation marks omitted). In ruling on a § 2255 petition, district courts are to hold a hearing “[u]nless the motion and the files and records of the case conclusively show that the [incarcerated individual] is entitled to no relief.” 22 U.S.C. § 2255(b). A hearing is also not necessary “where the allegations are vague, conclusory, or palpably incredible.” Gonzalez v. United States, 722 F.3d 118, 130 (2d Cir. 2013) (internal quotation marks omitted); see also Rosa v. United States, 170

F. Supp. 2d 388, 398 (S.D.N.Y. 2001) (no hearing necessary “where (1) the allegations of the motion, accepted as true, would not entitle the petitioner to relief or (2) the documentary record, including any supplementary submissions such as affidavits, render a testimonial hearing unnecessary.”) Therefore, to obtain a hearing under § 2255, “the motion must set forth specific facts supported by competent evidence, raising detailed and controverted issues of fact that, if proved at a hearing, would entitle him to relief.” Gonzalez, 722 F.3d at 131. A petitioner asserting ineffective assistance of counsel in a § 2255 petition must establish that (1) his “counsel’s performance was deficient” and (2) “the deficient performance prejudiced the defense.” Strickland v. Washington, 466 U.S. 668, 687 (1984). As for the first prong, a court “must judge [counsel’s] conduct on the basis of the facts of the particular case, viewed at the time of counsel’s conduct, and may not use hindsight to second-guess his strategy choices.” Mayo v. Henderson, 13 F.3d 528, 533 (2d Cir. 1994) (internal quotation marks omitted). There is a strong presumption that counsel’s conduct is within the range of reasonable professional

assistance. See Strickland, 466 U.S. at 689. As for the second prong, a petitioner must show “a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Strickland, 466 U.S. at 694. Where a petitioner’s claim involves a guilty plea, the petitioner “must show that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial.” Hill v. Lockhart, 474 U.S. 52, 59 (1985). Where a petitioner claims ineffective assistance at sentencing, he “must show a reasonable probability that, but for counsel’s substandard performance, he would have received a less severe sentence.” Gonzalez, 722 F.3d at 130 (internal citations omitted). II. Discussion

Defendant’s first argument is that his counsel provided ineffective assistance by failing to “object to the indictment” and because there was no “fair connection to an underlying criminal agreement between two or more people to commit a crime.” The indictment clearly charged the Defendant with engaging in a conspiracy to distribute and to possess with intent to distribute fentanyl “[o]n or about June 5, 2021, in the Southern District of New York and elsewhere.” This tracked the language of the applicable statutes and placed Defendant on notice of the charged crime. Defendant has shown no deficiency in the indictment and provides no reason to believe that a motion to dismiss the indictment would have had any merit. Further, in pleading guilty, Defendant confirmed that he understood each of the elements of the crime and that he had in fact committed the crime. Defendant has not shown ineffective assistance on the part of his counsel with respect to the indictment or that Defendant was prejudiced by the failure to move for its dismissal. Second, Defendant claims is that his counsel was ineffective because his counsel did not

consult with Defendant about filing an appeal and failed to file an appeal after Defendant requested one. “[I]n order to show that appellate counsel was constitutionally deficient in not filing an appeal, the petitioner must demonstrate that he asked to have an appeal filed.” McHale v. United States, 175 F.3d 115, 119 (2d Cir. 1999). In addition, “counsel has a constitutionally imposed duty to consult with the defendant about an appeal when there is reason to think either (1) that a rational defendant would want to appeal (for example, because there are nonfrivolous grounds for appeal), or (2) that this particular defendant reasonably demonstrated to counsel that he was interested in appealing.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Roe v. Flores-Ortega
528 U.S. 470 (Supreme Court, 2000)
Yick Man Mui v. United States
614 F.3d 50 (Second Circuit, 2010)
United States v. William Bokun
73 F.3d 8 (Second Circuit, 1995)
Kevin McHale v. United States
175 F.3d 115 (Second Circuit, 1999)
Gonzalez v. United States
722 F.3d 118 (Second Circuit, 2013)
Rosa v. United States
170 F. Supp. 2d 388 (S.D. New York, 2001)
Santiago v. United States
187 F. Supp. 3d 387 (S.D. New York, 2016)
Carrasco v. United States
190 F. Supp. 3d 351 (S.D. New York, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Cruz-Polanco v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cruz-polanco-v-united-states-nysd-2024.