Hernandez-Lopez v. United States

CourtDistrict Court, D. Nevada
DecidedJanuary 22, 2021
Docket2:20-cv-01162
StatusUnknown

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

Bluebook
Hernandez-Lopez v. United States, (D. Nev. 2021).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 United States of America, Case No.: 2:15-cr-00036-JAD-CWH

4 Plaintiff Order Denying Motion to Vacate § 924 5 v. Conviction under United States v. Davis and Granting Motion to File Sur-reply 6 Oscar Hernandez-Lopez, [ECF Nos. 127, 131] 7 Defendant 8

9 In early 2017, Oscar Hernandez-Lopez pled guilty to several charges for a series of 10 robberies he committed years before.1 The charges included brandishing a firearm during a 11 crime of violence in violation of 18 U.S.C.§ 924(c)(1)(A) and three counts of interference with 12 commerce by robbery under the Hobbs Act.2 As part of his plea agreement, Hernandez-Lopez 13 waived his right to challenge his sentence on direct appeal or collateral attack under 28 U.S.C. 14 § 2255.3 Hernandez-Lopez received a within-guidelines sentence of 72 months for the robbery 15 and conspiracy counts, plus 84 months for the firearm count, for a total sentence of 156 months.4 16 At the time of Hernandez-Lopez’s conviction, § 924(c) offered two ways for an 17 underlying offense to constitute a “crime of violence.” But in 2019, the United States Supreme 18 Court struck down one of them as unconstitutionally vague in United States v. Davis.5 While 19 Hernandez-Lopez did not appeal, he now asks this court to vacate his firearm conviction under 20

21 1 ECF Nos. 92, 93. 2 18 U.S.C. § 1951(b)(1). 22 3 ECF No. 93. 23 4 ECF No. 99. 5 United States v. Davis, 139 S. Ct. 2319 (2019). 1 § 2255, arguing that, under Davis, neither aiding and abetting nor completing a Hobbs Act 2 robbery is a crime of violence. I deny Hernandez-Lopez’s motion because he was convicted as a 3 principal and the Ninth Circuit has since held that Hobbs Act robbery is a crime of violence 4 under § 924(c)’s remaining clause,6 so his conviction remains valid despite the Davis holding. 5 Discussion

6 Section 924(c) carries heightened criminal penalties for defendants who use, carry, or 7 possess a firearm during and in relation to a “crime of violence.” The statute defines “crime of 8 violence” in two subsections. First, the “elements clause” defines a crime of violence to include 9 a felony that “has as an element the use, attempted use, or threatened use of physical force 10 against the person or property of another.”7 Second, the “residual clause” includes any felony 11 “that[,] by its nature, involves a substantial risk that physical force against the person or property 12 of another may be used in the course of committing the offense.”8 But in 2019, the High Court 13 held in United States v. Davis that the residual clause’s crime-of-violence definition is 14 unconstitutionally vague.9

15 Relying on Davis, Hernandez-Lopez contends that his § 924(c) conviction must be 16 vacated because neither aiding and abetting a Hobbs Act robbery nor a completed robbery 17 constitutes a crime of violence.10 The government opposes his motion, arguing that Hernandez- 18 19 6 I find that no evidentiary hearing is warranted in light of clear Ninth Circuit authority. 20 7 18 U.S.C. § 924(c)(3)(A). 21 8 Id. § 924(c)(3)(B). 9 Davis, 139 S. Ct. at 2336. 22 10 Hernandez-Lopez also argues that his habeas petition is timely because Davis announced a new rule that alters the range of conduct and class of persons that can be punished under 23 § 924(c). ECF No. 127 at 4–5. Because the government does not dispute this point, I assume without deciding that the petition is timely, and I deny it for other reasons. 1 Lopez waived his opportunity to challenge this conviction. It adds that his challenge is 2 procedurally defaulted and fails on its merits because the Ninth Circuit recently foreclosed such a 3 challenge in United States v. Dominguez11 when it held that Hobbs Act robbery remains a crime 4 of violence under § 924’s elements clause. 5 I. Hernandez-Lopez didn’t waive this collateral challenge.

6 The government contends that Hernandez-Lopez waived his right to challenge his 7 § 924(c) conviction in his written-plea agreement, which includes an express waiver to bring any 8 collateral challenges including those brought under 28 U.S.C. § 2255.12 But as the government 9 concedes, in the Ninth Circuit, “[a] waiver of appellate rights will . . . not apply if a defendant’s 10 sentence is ‘illegal,’ which includes a sentence that ‘violates the Constitution.’”13 Because 11 Hernandez-Lopez argues that Davis invalidated his § 924(c) conviction and alternatively that his 12 § 924(c) conviction is illegal under the remaining elements clause, his plea waiver doesn’t bar 13 this motion. 14 II. Hernandez-Lopez procedurally defaulted his claim for relief.

15 A defendant who fails to raise a claim on direct review is deemed to have procedurally 16 defaulted it and may only raise it later in a habeas petition if he can demonstrate cause and actual 17 prejudice, or actual innocence.14 The government argues that Hernandez-Lopez’s motion, which 18 comes more than three years after the deadline to appeal expired, was inexcusably tardy because 19 his argument was available to him before Davis was decided and he can’t show prejudice 20 because a Hobbs Act robbery remains a crime of violence in the Ninth Circuit. Hernandez- 21 11 United States v. Dominguez, 954 F.3d 1251, 1255 (9th Cir. 2020). 22 12 ECF No. 129 at 13–14; ECF No. 93 at 13. 23 13 United States v. Torres, 828 F.3d 1113, 1125 (9th Cir. 2016); ECF No. 129 at 14 n.1. 14 Bousley v. United States, 523 U.S 614, 622 (1998) (citations omitted). 1 Lopez responds that the procedural-default rule doesn’t apply to his motion because his claim is 2 based on a jurisdictional defect. He adds that cause exists because his Davis-based argument 3 wasn’t available to him during the window to appeal. Hernandez-Lopez bears the burden to 4 show cause and prejudice, and he has failed to do so. 5 A. Hernandez-Lopez’s jurisdictional-defect argument is without merit.

6 Hernandez-Lopez argues that his claim is exempt from the procedural-default rule 7 because it ultimately challenges this court’s jurisdiction. He cites United States v. Montilla15 for 8 the proposition that his claim challenges the constitutionality of applying the Hobbs Act to 9 § 924(c) and that the indictment fails to state an offense.16 The Ninth Circuit’s holding in United 10 States v. Chavez-Diaz17 forecloses this argument. In Chavez-Diaz, the court explained that the 11 jurisdictional exception “applies ‘where on the face of the record the court had no power to enter 12 the conviction or impose the sentence.’”18 Thus, these limited challenges are predicated on 13 scenarios “where [an] appeal, if successful, would mean that the government cannot prosecute 14 the defendant at all.”19 Hernandez-Lopez’s challenge does not raise a jurisdictional defect

15 excused from the procedural-default rule because he doesn’t argue that the government lacked 16 the power to prosecute him for these acts or that Congress lacked the power to pass either 17 statute.20 18 19

20 15 United States v. Montilla, 870 F.2d 549 (9th Cir. 1989). 21 16 ECF No. 130 at 4. 17 United States v.

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Hernandez-Lopez v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hernandez-lopez-v-united-states-nvd-2021.