Gomez v. United States

CourtDistrict Court, E.D. Wisconsin
DecidedDecember 27, 2024
Docket2:23-cv-00339
StatusUnknown

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

Bluebook
Gomez v. United States, (E.D. Wis. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

LUIS F. GOMEZ,

Petitioner, Case No. 23-cv-339-pp v.

UNITED STATES OF AMERICA,

Respondent.

ORDER DENYING PETITIONER'S §2255 MOTION TO VACATE, SET ASIDE OR CORRECT SENTENCE (DKT. 1), DECLINING TO ISSUE CERTIFICATE OF APPEALABILITY AND DISMISSING CASE

On March 14, 2023, the petitioner, who is representing himself, filed a motion under 28 U.S.C. §2255, asking the court to vacate, set aside or correct the sentence imposed in United States v. Gomez, Case No. 17-cr-113 (E.D. Wis.) on the grounds that he received ineffective assistance of counsel and an improper sentencing enhancement. Dkt. No. 1. The government opposes the motion, arguing that counsel’s performance was not ineffective and that challenges to the sentencing guidelines are not cognizable under §2255. Dkt. No. 4. The court will deny the petitioner’s motion, decline to issue a certificate of appealability and dismiss the motion (and the case). I. Background A. Underlying Case On June 20, 2017, the grand jury returned an indictment against the petitioner and his co-defendants in Case No. 17-cr-113. Dkt. No. 1. Count One charged the petitioner with knowingly and intentionally conspiring to distribute one kilogram or more of heroin, five kilograms or more of cocaine and fifty grams or more of methamphetamine in violation of 21 U.S.C. §§841(a)(1), 841(b)(1)(a) and 846 and with aiding and abetting the conspiracy in violation of

18 U.S.C. §2. Id. at 2. On November 12, 2019, after a six-day trial, a jury found the petitioner and his co-defendant, Pablo Hidalgo-Sanchez, guilty of Count One of the indictment. Dkt. No. 629. The court sentenced the petitioner to 168 months (fourteen years) in prison followed by five years of supervised release. Dkt. No. 891. The court entered judgment on January 26, 2021. Dkt. No. 892. On January 27, 2021, the petitioner filed a notice of appeal. Dkt. No. 894. On appeal, the petitioner argued that the government’s impermissible use of bolstering testimony warranted a new trial. Dkt. No. 1002 at 28. On March

31, 2022, the Seventh Circuit affirmed the petitioner’s conviction, finding that although the government had impermissibly introduced bolstering testimony at trial, the presentation of the testimony did not constitute plain error. Id. at 34. B. Motion to Vacate, Set Aside or Correct Sentence (Dkt. No. 1) On March 14, 2023, the petitioner filed the instant §2255 motion arguing that he was deprived of his right to effective assistance of counsel in violation the Fifth, Sixth, Eighth and Fourteenth Amendments. Dkt. No. 1 at 2–3. The

petitioner says that his counsel was ineffective by: giving him bad advice that caused him to reject a plea offer and go to trial, thereby losing the opportunity for a more favorable sentence; failing to file timely objections to the presentence investigation report; failing to perfect the record on appeal; and failing to present sufficient and credible evidence during trial and at sentencing to show that an aggravating role sentencing enhancement under USSG §3B1.1(a) was improperly calculated. Id. at 4. The petitioner also requests an evidentiary hearing. Id. at 8–9.

The petitioner first argues that his counsel failed to advise him that “it was in his best interest to plea[d] guilty.” Dkt. No. 1 at 4. The petitioner contends that he was “not informed of the very high probability that he would lose the trial” and that counsel led him to believe that he would face the same amount of prison time as was offered in the plea agreement should he be found guilty at trial. Id. at 4–5. Specifically, the petitioner states that counsel advised him to reject the government’s plea deal (to a charge that carried a ten-year mandatory minimum) because the district court would sentence the petitioner

to only ten years if he lost at trial. Id. at 5. The petitioner states that counsel’s performance was deficient because the lawyer was “unfamiliar with the sentencing guidelines and substantially misstated [petitioner’s] exposure.” Id. at 5–6. The petitioner next argues that the court improperly applied a four-level sentencing enhancement under USSG §3B1.1(a) and that his counsel failed to object to the enhancement. Id. at 6–7. The petitioner argues that the

sentencing enhancement applies to a defendant who was an “organizer or leader of a criminal activity that involved 5 or more participants, or was otherwise extensive.” Id. He asserts that the factual basis for this enhancement was not established at trial or at the sentencing hearing. Id. at 7. The petitioner asks the court to correct his sentence to reflect a guideline range without the enhancement. Id. at 8. According to the petitioner, his sentence should be reduced to 120 months to match the low end of the revised guideline range. Id. The petitioner argues that his sentence was increased based on counsel’s

deficient performance and failure to object to the enhancement. Id. Finally, the petitioner asks for an evidentiary hearing, arguing that such a hearing is the “default” unless his claim is manifestly invalid from the face of the record. Id. at 8–9. The government responded to the petition, arguing that the petitioner received effective assistance of counsel. Dkt. No. 4 at 4. The government asserts that the plea offer the petitioner mentioned identified a mandatory minimum ten-year sentence, but calculated the sentencing guidelines using a

base offense level of 34 and an additional 4-level enhancement under §3B1.1(a) for being a leader or organizer in a criminal activity. Id. (citing Dkt. No. 4-1). The government maintains that the petitioner’s counsel properly advised him that the guideline range would be the same whether he plead guilty or was found guilty at trial. Id. According to the government, the only benefit the petitioner lost from declining the plea offer was the 3-level reduction for acceptance of responsibility under §§3E1.1(a) and (b). Id. The government

recounts that the court sentenced the petitioner to 168 months of incarceration, which the government argues corresponds to the low end of the guideline range calculated in the plea offer. Id. The government argues that even if counsel’s performance was deficient, the petitioner cannot establish prejudice because the sentence he received would have been presumptively reasonable under the plea agreement. Id. at 5. Next, the government argues that the petitioner cannot challenge the sentencing enhancement on a §2255 motion. Id. The government maintains

that a misapplication of the sentencing guidelines does not raise a constitutional issue, deprive the court of jurisdiction or constitute an assertion that the judge exceeded the statutory maximum. Id. (quoting Scott v. United States, 997 F2d 340, 341 (7th Cir. 1993); Buggs v. United States, 153 F.3d 439, 443 (7th Cir. 1998)). It argues that because the sentencing guidelines are “advisory,” an erroneous calculation does not provide a basis for relief under §2255. Id. at 6. According to the government, the sentencing judge must independently consider whether a guideline sentence is consistent with the 18

U.S.C. §3553(a) factors. Id. The government also opposes the petitioner’s request for an evidentiary hearing. Id.

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Gomez v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gomez-v-united-states-wied-2024.