Franklyn Morillo v. United States of America

2020 DNH 207
CourtDistrict Court, D. New Hampshire
DecidedNovember 30, 2020
Docket20-cv-164-SM
StatusPublished
Cited by1 cases

This text of 2020 DNH 207 (Franklyn Morillo v. United States of America) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Franklyn Morillo v. United States of America, 2020 DNH 207 (D.N.H. 2020).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Franklyn Morillo

v. Case No. 20-cv-164-SM Opinion No. 2020 DNH 207 United States of America

ORDER

Petitioner providently pled guilty to participating in a

drug distribution conspiracy. He and his wife operated a

substantial drug distribution business from their home in

Haverhill, Massachusetts. His plea was offered under a written

agreement with the government in which the parties stipulated

(Fed. R. Cr. P. 11(c)(1)(C)) that the Guidelines calculation in

his case would start with a base offense level of not less than

26 nor more than 30, depending on the drug weight attributable

to Petitioner.

The pre-sentence investigation report conservatively

estimated the attributable drug weight and the court determined

that the correct base offense level was 30, within the range

stipulated. Petitioner was sentenced, inter alia, to 168 months

in prison, a sentence at the low end of the applicable

Guidelines range. Petitioner appealed his sentence, seeking to

1 challenge enhancements under the Guidelines, as well as some

supervised release conditions imposed. The appeal was deemed

barred by the waiver provisions included in his written

agreement with the government. United States v. Morillo, 910

F.3d 1 (1st Cir. 2018).

Petitioner now seeks similar relief, under 28 U.S.C. §

2255, on an ineffective assistance of counsel theory. He argues

that defense counsel 1) should have challenged the drug weight

attributable to him, as well as the leadership enhancement and a

premises or “stash house” enhancement, at sentencing; 2)

incorrectly advised him that he could be responsible for all

drugs involved in the conspiracy rather than just those

reasonably foreseeable to him; 3) failed to advise him of his

right to testify at sentencing, which he claims he would have

exercised; 4) failed to challenge conditions of supervised

release imposed; and, 5) generally failed to advise him that he

could plead guilty with no plea agreement and did not adequately

discuss the advantages and disadvantages of proceeding to trial

rather than pleading guilty.

Petitioner’s Burden - Ineffective Assistance

To prevail on an ineffective assistance of counsel claim, a

petitioner must show two things: First, that counsel’s

2 representation fell below an objective threshold of reasonable

care, and second, that he was prejudiced by that deficient

performance. See Strickland v. Washington, 466 U.S. 668, 687

(1984). The prejudice test is met only if Petitioner shows that

there is a reasonable probability that the outcome of the

proceedings would have been different but for counsel’s

deficient representation. Id.

In this case, Petitioner also seems to challenge the

providence of his guilty plea, saying he would not have pled

guilty if he had been advised by counsel of the advantages and

disadvantages of going to trial, or if he had been properly

advised that he would be held accountable under the Guidelines

only for those drug quantities involved in the conspiracy that

were reasonably foreseeable to him (instead of the full amount).

He further says that he would have negotiated an agreement that

did not include a waiver of his appellate rights had he been

told of that option. To the extent Petitioner challenges his

guilty plea, in order to meet the Strickland prejudice test, he

must demonstrate “a reasonable probability that but for

counsel’s errors, he would not have pled guilty and would have

insisted on going to trial.” Hill v. Lockhart, 474 U.S. 52, 59

(1984).

3 Discussion

Failure to Contest the Attributable Drug Quantities

Defense counsel’s acceptance of the drug quantities

estimated by the probation officer - and communicated in the

presentence investigation report, was not only reasonable and

well within the bounds of adequate representation, but, had

counsel “put the government to its proof,” as Petitioner claims

he should have done, that would have likely qualified as

ineffective assistance. It cannot be rationally disputed that

the evidence would easily have supported a much higher estimate

of drug quantities reasonably foreseeable to Petitioner. That

evidence included Petitioner’s own statements to police, and,

those captured on wiretaps, as well as the testimony of co-

conspirators. Petitioner was held accountable for only one year

of drug dealing, when he himself admitted that he had been

dealing for years, and, the attributed quantities during that

year were substantially less than quantities he himself had

acknowledged.

Had defense counsel made an issue of it, the government

would have been given the opportunity to present that evidence

and the resulting offense level would have been higher. Without

question, Petitioner would have lost the benefit of his plea

bargain, and would have been facing greater exposure to a much

4 longer sentence, which he likely would have received. Counsel’s

decision was wise, and, certainly no prejudice can be shown,

given the predictable adverse results for Petitioner had counsel

not accepted the conservative quantity estimates.

The Enhancements for Role in the Offense and Premises Use (“stash house”)

Defense counsel objected to each enhancement based on the

undisputed evidence and made appropriate legal arguments

supporting his objections. That his objections were not

sustained does not alter the fact that his representation fell

well within the bounds of reasonable and competent

representation. Petitioner’s claims that counsel should have

done more (call witnesses, call the Petitioner, etc.) are

unaccompanied by any proffer that would undermine in any way the

rulings on those enhancements. The record is clear and supports

both enhancements, and counsel vigorously and appropriately

challenged their imposition, within the bounds of reasonable

representation. Counsel was not ineffective in that regard, and

Petitioner cannot show prejudice, as he cannot demonstrate a

reasonable probability that but for counsel’s actions the

outcome would have been different.

5 Failure to Properly Advise of Right to Testify at Sentencing; Properly Advise About Drug Quantity Attribution; to Properly Advise of Possible Guilty Plea Without an Agreement Containing a Waiver of Appellate Rights or of the Advantages or Disadvantages of Going to Trial Rather Than Plead Guilty; and, Failure to Call Mitigation Witnesses

Petitioner asserts that defense counsel did not advise him

of his right to testify at sentencing. Had counsel so advised,

he says he would have exercised his right and testified in

opposition to the drug weights ascribed to him, the enhancement

for using his home to deal drugs, and the enhancement for his

supervisory role in the distribution conspiracy.

“A criminal defendant’s right to testify on his own behalf

– or, conversely, not to testify – is a critically important

right. Given the salience of the right, a defendant is entitled

to be fully briefed so that he may make an informed choice.”

Casiano-Jimenez v. United States, 817 F.

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Related

Morillo v. United States
D. New Hampshire, 2020

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