Hernandez v. United States

CourtDistrict Court, D. Utah
DecidedJune 15, 2022
Docket2:22-cv-00219
StatusUnknown

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

Bluebook
Hernandez v. United States, (D. Utah 2022).

Opinion

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH

ESPERANZA APRIL HERNANDEZ MEMORANDUM DECISION Plaintiff, AND ORDER

v. Case No. 2:22-CV-219-HCN

UNITED STATES OF AMERICA, Howard C. Nielson, Jr. United States District Judge Defendant.

On January 25, 2021, Esperanza April Hernandez pled guilty to one count of conspiracy to distribute methamphetamine in violation of 21 U.S.C. §§ 841(a) and 846. See Case. No. 2:20- cr-197, Dkt. No. 349. She entered this plea pursuant to an agreement under Federal Rule of Criminal Procedure 11(c)(1)(c), as part of which Ms. Hernandez and the Government stipulated to a sentence of 192 months’ incarceration (16 years). See Dkt. No. 350 at 4. The Government also agreed not to seek a sentencing enhancement under 21 U.S.C. §§ 841(b)(1)(A) and 851. See id. at 5. On April 13, 2021, after careful consideration of the parties’ submissions and arguments and the sentencing factors set forth in 18 U.S.C. § 3553(a), the court found “that the proposed sentence is reasonable and appropriate and accept[ed] the proposed plea agreement.” Dkt. No. 448. Ms. Hernandez now seeks a sentence reduction under 28 U.S.C. § 2255. See Case No. 2:22- cv-219, Dkt. No. 1 at 12. Ms. Hernandez contends that the court should reconsider her sentence because she received ineffective assistance of counsel. She argues that her counsel was ineffective in three respects. Specifically she argues that he (1) failed to conduct an adequate investigation and reviewed only a small portion of her discovery file before advising her to accept the Government’s plea offer, (2) did not object to the proposed sentence or argue for a downward variance, and (3) pressured her into accepting the plea agreement by incorrectly advising that she was “looking at 30–life” if she did not “take a plea deal fast.” Id. at 4–6. In effect, Ms. Hernandez’s arguments amount to three distinct claims of ineffective assistance of counsel. To prevail on such a claim, a party generally “must prove both that: (1) his attorney’s ‘representation fell below an objective standard of reasonableness,’ and (2) ‘there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.’” United States v. Maley, 1 F.4th 816, 820 (10th Cir. 2021) (quoting Strickland v. Washington, 466 U.S. 668, 687–88, 694 (1984)). The court will address each of Ms. Hernandez’s

claims of ineffective assistance of counsel, starting with her second and third claims. The court rejects Ms. Hernandez’s second claim—that her counsel failed to object to the proposed sentence or argue for a downward variance. Ms. Hernandez received the “specific sentence” jointly recommended by the Government and the defense pursuant to a plea agreement under Federal Rule of Criminal Procedure 11(c)(1)(C). “[S]uch a recommendation . . . binds the court once the court accepts the plea agreement.” Id. Given the nature of the plea agreement, there was no basis for Ms. Hernandez’s counsel to object to the agreed-upon sentence. In addition, the agreed-upon sentence of 192 months’ incarceration itself reflected a significant downward variance from the guidelines range of 235–293 months’ imprisonment reflected in the

Pre-Sentence Report and accepted by the court—although as discussed below, the Report may well have improperly omitted considerations from the offense-level calculation that would have resulted in a higher guidelines range. In support of the significant downward variance reflected in the jointly recommended sentence, the Government argued that “Ms. Hernandez ha[d] entered a guilty plea and accepted responsibility for her actions,” that her criminal record had been “fueled by difficult formative years and years of substance abuse,” and that “her difficult personal history, her health challenges, and her drug addiction” warranted a sentence well below the guidelines range. Dkt. No. 443 at 4–5. Defense counsel made similar arguments at the sentencing hearing,1 and the court accepted the proposed plea agreement based on these arguments. Indeed, based on the facts and circumstances of the offense of conviction set forth in the Pre-Sentence Report—including the serious nature of the offense and Ms. Hernandez’s leadership role—the court almost certainly would have imposed a higher sentence but for the Rule 11(c)(1)(C) agreement and counsel’s

arguments. Under these circumstances, the court cannot say that Ms. Hernandez’s representation was objectively unreasonable or that she suffered any prejudice from the shortcomings she alleges. The court thus rejects this claim. The court likewise rejects Ms. Hernandez’s third claim—that counsel provided ineffective assistance by urging her to accept the plea agreement because she would face a potential sentence of thirty years to life imprisonment if she did not. According to the Pre- Sentence Report, which the court adopted without objections, see Dkt. No. 448, Ms. Hernandez had a base offense level of 36 and a criminal history category of VI. See Dkt. No. 450 at 17, 30. Absent an adjustment for acceptance of responsibility, these numbers would have resulted in a

guideline range of 324 to 405 months’ imprisonment. See U.S. Sentencing Guidelines Manual,

1 Although the parties have not requested a transcript of the sentencing hearing, the court has reviewed the recording of the hearing to confirm that Defense counsel made such arguments. ch. 5, pt. A (sentencing table). Given Ms. Hernandez’s criminal history category, a mere one- level increase in her offense level would have sufficed to generate a guidelines range of 360 months to life. See id. To be sure, Ms. Hernandez’s counsel’s calculation of the potentially applicable guidelines range differed slightly from that later reached by the Probation Office and accepted by the court. But even if the latter calculation was correct and counsel’s calculation was incorrect, given how close the base offense level and Ms. Hernandez’s criminal history brought her to the guidelines range predicted by counsel, the court cannot say that counsel’s calculation, made more than two months before the Pre-Sentence Report was created, fell below the level of objectively reasonable representation.

In all events, based on further review, the court is not convinced that counsel’s calculation was incorrect. Although the Pre-Sentence Report calculated Ms. Hernandez’s guidelines range using a base offense level of 36 reduced by three levels for acceptance of responsibility, the Report also indicates that Ms. Hernandez issued directions to at least three of her co-defendants. See Dkt. No. 450 at 5–6, 7–8, 14. And the Sentencing Guidelines instruct that Based on the defendant’s role in the offense, increase the offense level as follows:

(a) If the defendant was an organizer or leader of a criminal activity that involved five or more participants or was otherwise extensive, increase by 4 levels.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Jae Lee v. United States
582 U.S. 357 (Supreme Court, 2017)

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Hernandez v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hernandez-v-united-states-utd-2022.