Cruz-Ramos v. United States

CourtDistrict Court, D. Puerto Rico
DecidedJune 5, 2025
Docket3:21-cv-01439
StatusUnknown

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

Bluebook
Cruz-Ramos v. United States, (prd 2025).

Opinion

FOR THE DISTRICT OF PUERTO RICO

ISMAEL E. CRUZ-RAMOS,

Petitioner,

Civil No. 21-1439 (ADC) v. [Related to Crim. No. 12-200-9 (ADC)]

UNITED STATES OF AMERICA,

Respondent.

OPINION AND ORDER Pending before the Court is petitioner Ismael E. Cruz-Ramos’ (“petitioner”) pro se motion to vacate, set aside, or correct sentence pursuant to 28 U.S.C. § 2255, filed on September 10, 2021. ECF No. 1 (“Mot.”). The United States of America (“government”) opposed plaintiff’s motion. ECF No. 9. Petitioner filed a reply, followed by a motion for leave to supplement. ECF Nos. 10, 18. In addition, in compliance with a Court order, petitioner’s trial counsel, Attorney Francisco Adams-Quesada, filed a response to petitioner’s motion. ECF No. 17. Petitioner’s motion levies five separate ineffective assistance of counsel claims against both his trial and appellate attorneys. When measured under Strickland v. Washington, 466 U.S. 668 (1984), petitioner’s claims fail to hold water. Accordingly, having considered the above filings and for the ensuing reasons, the Court DENIES petitioner’s motion.1

1 The Court has already advanced its ruling to petitioner denying his motion. ECF No. 19. This Opinion and Order provides the Court’s reasoning. I. Factual Background. For context, the Court rehearses the relevant proceedings and underlying facts that relate to petitioner’s ineffective assistance of counsel claims. A. Petitioner’s 2011 federal conviction for harboring a fugitive.

Petitioner’s legal ordeal began on August 28, 2010, when he was arrested for harboring a fugitive and his future co-defendant, Bernard Astacio-Espino (“Astacio-Espino”), in his house. See Compl., United States v. Cruz-Ramos, Crim. No. 10-305 (JAG) (D.P.R. Aug. 29, 2010), ECF No.

2.2 Petitioner was indicted on September 2, 2010 and later plead not guilty to the charge. Crim. No. 10-305, ECF Nos. 9, 11. He was represented by a Court-appointed attorney throughout the process. See Crim. No. 10-305, ECF Nos. 5, 14, 45. On November 16, 2010, petitioner moved to change his plea. Crim. No. 10-305, ECF No.

20. On December 12, 2010, petitioner signed a plea agreement and a statement of facts in which he admitted to, among other things, knowing Astacio-Espino, knowing that he had an outstanding arrest warrant, and knowing that he had stayed several times at his residence

without alerting the police. Crim. No. 10-305, ECF No. 26. On March 8, 2011, the Court sentenced petitioner to a term of imprisonment of twelve months and one day, crediting time already served, and to three years of supervised release. Crim. No. 10-305, ECF No. 39. His supervised

release was conditioned on him not committing another federal, state or local crime. Id., at 3.

2 All references to the docket of United States v. Ramos-Cruz, Crim. No. 10-305, shall hereinafter be “Crim. No. 10- 305” followed by the applicable electronic docket entry, so as to distinguish these from references to the above- captioned civil case docket. Petitioner did not appeal his sentence, as a result of which it became final and unappealable. See United States v. Ciampi, 419 F.3d 20, 23 n.2 (1st Cir. 2005) (when a defendant fails to appeal his conviction, the sentence becomes final “when the court enter[s] judgment on the plea agreement.”).3

Petitioner was released from custody on July 13, 2011. Crim. No. 10-305, ECF No. 40. On December 2, 2011, the United States Probation Office filed an informative motion notifying the Court of petitioner’s violation of his supervised release conditions, given that he was arrested

and charged on October 11, 2011 with violations of several federal drug trafficking and firearm statutes. Id. B. Petitioner’s 2013 and 2017 RICO and VICAR trials and conviction. On March 20, 2012, a Grand Jury returned an indictment against petitioner and 32 other

co-defendants as part of an operation against a drug trafficking organization known as “La ONU,” charging them with a litany of drug trafficking and firearm offenses. Crim. No. 12-200, ECF No. 1.4 Petitioner was brought before a United States Magistrate Judge for an initial

appearance. Crim. No. 12-200, ECF No. 56. The Court appointed Attorney Adams-Quesada to

3 But see, e.g., Hernández-López v. United States, No. CV 20-1128 (SCC), 2022 WL 4220193, at *1 (D.P.R. Sept. 12, 2022) (identifying possible disagreement of other circuit courts with Ciampi as to whether one-year limitations period for Section 2255 relief begins to run upon entry of judgment or when time to appeal expires under Fed. R. App. P. 4(b)(1)); Guerrero-Feliciano v. United States, No. CV 20-1027 (ADC), 2023 WL 2713900, at *3 (D.P.R. Mar. 30, 2023) (same). 4 All references to the docket of United States v. Ramos-Pineiro, et al., Crim. No. 12-200 (D.P.R.), shall hereinafter be “Crim. No. 12-200” followed by the applicable electronic docket entry, so as to distinguish these from references to the above-captioned civil case docket. represent him pursuant to the Criminal Justice Act. Crim. No. 12-200, ECF No. 40. Petitioner was then arraigned on April 13, 2012 and plead not guilty. Crim. No. 12-200, ECF No. 93. The government filed a Superseding Indictment on June 20, 2012, where it charged petitioner with one count of RICO conspiracy in violation of 18 U.S.C. § 1962(d) (“Count 1”);

conspiracy to possess with intent to distribute controlled substances in violation of 21 U.S.C. §§ 846 and 860 (“Count 2”); conspiracy to possess firearms during and in relation to a drug trafficking crime in violation of 18 U.S.C. § 924(o) (“Count 3”); aiding and abetting in the murder

of Christian Toledo Sánchez, a/k/a “Pekeke,” in violation of Puerto Rico Penal Code articles 105 and 106 (2004) as a violent crime in aid of racketeering activity (“VICAR”) under 18 U.S.C. § 1959(a)(1) (“Count 29”); and aiding and abetting the use and carry of a firearm in relation to a crime of violence under 18 U.S.C. §§ 924(c)(1)(A), 924(j)(1) and (2) (“Count 30”). Crim. No. 12-

200, ECF No. 196. Petitioner again plead not guilty at his second arraignment. Crim. No. 12-200, ECF No. 221. Petitioner was tried alongside co-defendants Pedro L. Ramírez-Rivera and José

Laureano-Salgado. Trial took place before an anonymous jury between February 7 and 15, 2013 and lasted seven days. Crim. No. 12-200, ECF Nos. 749, 792. After the evidence was heard, the jury deliberated for half a day and found petitioner guilty on all counts charged . Crim. No. 12-

200, ECF Nos. 792, 794. On October 2, 2013, petitioner was sentenced to life imprisonment without the possibility of parole as to Count 29, twenty years imprisonment as to Count 3, to run concurrently with Count 29, and twenty additional years imprisonment as to Count 30, to run consecutively to Count 29, for a total term of life plus twenty years. Crim. No. 12-200, ECF No. 1204.

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)
Evitts v. Lucey
469 U.S. 387 (Supreme Court, 1985)
Pennsylvania v. Finley
481 U.S. 551 (Supreme Court, 1987)
Smith v. Robbins
528 U.S. 259 (Supreme Court, 2000)
Apprendi v. New Jersey
530 U.S. 466 (Supreme Court, 2000)
United States v. Booker
543 U.S. 220 (Supreme Court, 2004)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Tevlin v. Spencer
621 F.3d 59 (First Circuit, 2010)
United States v. Mala
7 F.3d 1058 (First Circuit, 1993)
United States v. Spinney
65 F.3d 231 (First Circuit, 1995)
United States v. Campbell
108 F. App'x 1 (First Circuit, 2004)
Ciampi v. United States
419 F.3d 20 (First Circuit, 2005)
Dugas v. Coplan
428 F.3d 317 (First Circuit, 2005)
Janosky v. St. Amand
594 F.3d 39 (First Circuit, 2010)
Jose Rosado Acha v. United States
910 F.2d 28 (First Circuit, 1990)
Moreno-Espada v. United States
666 F.3d 60 (First Circuit, 2012)
Mayle v. Felix
545 U.S. 644 (Supreme Court, 2005)
Alleyne v. United States
133 S. Ct. 2151 (Supreme Court, 2013)
Rosemond v. United States
134 S. Ct. 1240 (Supreme Court, 2014)
United States v. Davis
750 F.3d 1186 (Tenth Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Cruz-Ramos v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cruz-ramos-v-united-states-prd-2025.