Griego v. United States

CourtDistrict Court, D. New Mexico
DecidedJune 17, 2025
Docket1:23-cv-00190
StatusUnknown

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

Bluebook
Griego v. United States, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW MEXICO

DENNIS GRIEGO,

Movant, v. 1:23-cv-00190-WJ-JMR

UNITED STATES OF AMERICA,

Respondent.

PROPOSED FINDINGS AND RECOMMENDED DISPOSITION

THIS MATTER comes before the Court on Dennis Griego’s Motion to Vaca te Sentence Under 28 U.S.C. § 2255. Doc. 1. The United States filed a response, as ordered by the Court. Docs. 3, 7. Mr. Griego filed a reply. Doc. 10. Mr. Griego requested supplemental briefing, which the Court allowed. Docs. 11, 12. Mr. Griego filed a supplemental brief (Doc. 15), the United States filed a supplemental response (Doc. 20), and Mr. Griego filed a supplemental reply (Doc. 27). Senior District Judge William P. Johnson referred the case to me pursuant to 28 U.S.C. §§ 636(b)(1)(B) and (b)(3) to conduct hearings, if warranted, and to perform any legal analysis required to recommend to the Court an ultimate disposition of this case. Doc. 4. Having reviewed the parties’ submissions and the relevant law, I recommend that the Court deny Mr. Griego’s motion and deny a certificate of appealability. I. Background On July 5, 2018, Mr. Griego pleaded guilty to being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g). Doc. 60, United States v. Griego, No. 16-cr-3868-WJ-JMR (D.N.M. filed July 5, 2018). At his sentencing hearing, this Court was required to calculate Mr. Griego’s correct sentencing guideline range. Gall v. United States, 552 U.S. 38, 51 (2007). In doing so, it held that Mr. Griego qualified as an armed career criminal pursuant to the Armed Career Criminal Act (“ACCA”). Doc. 76 at 1, United States v. Griego, No. 16-cr-3868-WJ-JMR (D.N.M. filed March 22, 2019); see also 18 U.S.C. § 924(e). In other words, the Court found that Mr. Griego had “three previous convictions . . . for a violent felony or a serious drug offense, or both, committed on occasions different from one another.” 18 U.S.C. § 924(e). Because of the

ACCA application, Mr. Griego was subject to a mandatory minimum sentence of fifteen years’ (180 months’) imprisonment. Id. Without the ACCA enhancement, Mr. Griego would have faced a maximum statutory sentence of ten years’ (120 months’) imprisonment. Doc. 1 at 25; see also 18 U.S.C. § 922(g)(1). As part of his plea agreement with the government, Mr. Griego stipulated to a 188-month sentence of imprisonment pursuant to Federal Rule of Criminal Procedure 11(c)(1)(C). Doc. 60, United States v. Griego, No. 16-cr-3868-WJ-JMR, (D.N.M. filed Sept. 27, 2016). However, the Court rejected the parties’ agreement. Doc. 61, United States v. Griego, No. 16-cr-3868-WJ-JMR (D.N.M. filed July 5, 2018). The Court, instead, sentenced Mr. Griego to the mandatory minimum sentence of 180 months’ imprisonment.1 Doc. 75, United States v. Griego, No. 16-cr-

3868-WJ-JMR (D.N.M. filed Feb. 21, 2019); Doc. 76, United States v. Griego, No. 16-cr-3868- WJ-JMR (D.N.M. filed March 22, 2019).

1 There is some discrepancy between the parties’ briefs and the underlying Court documents as to whether Mr. Griego was sen tenced to 188 months’ imprisonment—as the plea agreement states and as Mr. Griego sets forth in his motion (Doc. 1 at 2)—or 180 months’ imprisonment as the sentencing minutes, the judgment, and the government states in its response (Doc. 7 at 2). To resolve this question, I looked to the hearing minutes and a transcript of the sentencing hearing. The minutes indicated that at the sentencing hearing this Court rejected the “11(c)(1)(C) plea agreement.” Doc. 61, United States v. Griego, No. 16-cr-3868-WJ-JMR (D.N.M. filed July 5, 2018). Such a rejection comports with a sentence that is different from the parties’ agreed-upon sentence of 188 months. In the transcript, the Court explicitly states it is rejecting the plea agreement and is sentencing Mr. Griego to 180 months’ imprisonment. Doc. 84 at 3–9, United States v. Griego, No. 16-cr-3868-WJ-JMR (D.N.M. filed Jan. 16, 2024). 2 Notably, at the time of sentencing, Mr. Griego had five prior convictions for offenses that appeared to qualify as ACCA predicates. Doc. 1 at 2; see 18 U.S.C. § 924(e). The five offenses were two residential burglaries, a commercial burglary, trafficking methamphetamines, and an aggravated battery. Doc. 1 at 2. At the sentencing hearing, the district court did not state which

convictions it relied on to find Mr. Griego ACCA eligible. See generally Doc. 84, United States v. Griego, No. 16-cr-3868-WJ-JMR (D.N.M. filed Jan. 16, 2024). II. Mr. Griego’s Claims Mr. Griego now challenges whether three of his five state court convictions count as ACCA predicate offenses. Doc. 1; see 18 U.S.C. § 924(e) (enhancing a sentence if a person has three previous convictions “for a violent felony or a serious drug offense, or both, committed on occasions different from one another”). First, Mr. Griego argues that his conviction for commercial burglary is not a “violent felony,” and therefore, is not an ACCA predicate. Doc. 1 at 24. Second, Mr. Griego argues that his drug trafficking conviction was not a “serious drug offense,” and therefore, is not an ACCA predicate. Id. at 25. Third, Mr. Griego argues that his

two residential burglaries occurred on the same “occasion,” and therefore, only one burglary counts as an ACCA predicate. Id. at 3–13. Finally, Mr. Griego also argues that his Fifth and Sixth Amendment rights were violated when a judge, not a jury, decided whether his two burglaries occurred on separate occasions. Id. at 14–23; Doc. 15 at 3–19. In the supplemental briefing, Mr. Griego further argues that the Supreme Court’s holding in Erlinger v. United Statesapplies retroactively to him. See 602 U.S. 821 (2024). In Erlinger, the Supreme Court held tha t a defendant is “entitled to have a jury resolve ACCA’s occasions inquiry unanimously and beyond a reasonable doubt.” Id. at 835.

3 As discussed below, Mr. Griego is correct that his commercial burglary and drug trafficking convictions are not ACCA predicate offenses. Infra § V.A–B. However, contrary to his third claim, his two prior residential burglaries did not occur on the same “occasion,” and therefore, were properly considered as two separate convictions under the ACCA. Infra § V.C.i.

Finally, because the Supreme Court’s decision Erlinger does not apply retroactively, Mr. Griego’s constitutional rights were not violated when a judge decided whether his two burglaries occurred on different occasion. Infra § V.C.ii. As a result, Mr. Griego is still convicted of three ACCA predicate offenses—the two residential burglaries and an aggravated battery2—and he remains subject to the ACCA mandatory minimum sentence. III. Section 2255 Review Under 28 U.S.C. § 2255

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

Related

United States v. Frady
456 U.S. 152 (Supreme Court, 1982)
Reed v. Ross
468 U.S. 1 (Supreme Court, 1984)
Teague v. Lane
489 U.S. 288 (Supreme Court, 1989)
Taylor v. United States
495 U.S. 575 (Supreme Court, 1990)
Bousley v. United States
523 U.S. 614 (Supreme Court, 1998)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Apprendi v. New Jersey
530 U.S. 466 (Supreme Court, 2000)
Massaro v. United States
538 U.S. 500 (Supreme Court, 2003)
Schriro v. Summerlin
542 U.S. 348 (Supreme Court, 2004)
Shepard v. United States
544 U.S. 13 (Supreme Court, 2005)
Whorton v. Bockting
549 U.S. 406 (Supreme Court, 2007)
Gall v. United States
552 U.S. 38 (Supreme Court, 2007)
Carachuri-Rosendo v. Holder
560 U.S. 563 (Supreme Court, 2010)
United States v. King
422 F.3d 1055 (Tenth Circuit, 2005)
United States v. Michel
446 F.3d 1122 (Tenth Circuit, 2006)
United States v. Harris
447 F.3d 1300 (Tenth Circuit, 2006)
United States v. Stearns
387 F.3d 104 (First Circuit, 2004)
United States v. Robert J. Rideout
3 F.3d 32 (Second Circuit, 1993)
Wood v. Milyard
132 S. Ct. 1826 (Supreme Court, 2012)
United States v. Delossantos
680 F.3d 1217 (Tenth Circuit, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Griego v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/griego-v-united-states-nmd-2025.