Herrera-Rueda v. United States

CourtDistrict Court, M.D. Florida
DecidedAugust 15, 2025
Docket8:25-cv-00368
StatusUnknown

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

Bluebook
Herrera-Rueda v. United States, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

WILLIAN HERRERA-RUEDA,

Petitioner,

v. Case No. 8:25-cv-368-WFJ-AAS Crim. Case No. 8:19-cr-348-WFJ-AAS

UNITED STATES OF AMERICA,

Respondent. ____________________________________/

ORDER Willian Herrera-Rueda moves under 28 U.S.C. § 2255 to vacate his conviction for conspiracy to possess with intent to distribute cocaine while on board a vessel subject to the jurisdiction of the United States, for which he serves a below-guidelines sentence of 204 months. (Civ. Doc. 1; Crim. Doc. 467) He claims counsel rendered constitutionally ineffective assistance during his plea proceedings and at sentencing. Because his claims lack merit, Herrera-Rueda is entitled to no relief. I. Background Herrera-Rueda pleaded guilty under a plea agreement to conspiracy to possess with intent to distribute five kilograms or more of cocaine while on board a vessel subject to the jurisdiction of the United States, in violation of 46 U.S.C. §§ 70503(a), 70506(a) and (b), and 21 U.S.C. § 960(b)(1)(B)(ii) (Count Two). (Crim. Doc. 1; Crim. Doc. 166) The United States agreed to dismiss from the indictment the remaining count against Herrera-Rueda, which charged him with conspiring to distribute cocaine into the United States (Count One). (Crim. Doc. 166 at 3) The United States agreed to recommend both a sentence at the low end of the guidelines range and a downward

departure or sentence reduction if it determined that Herrera-Rueda provided substantial assistance in the investigation or prosecution of others. (Id. at 5–7) The presentence report calculates an advisory guidelines range of 235 to 293 months based on Herrera-Rueda’s total offense level of 38 and his criminal history category of I. (Crim. Doc. 333 at ¶ 70) At sentencing, the district court overruled

Herrera-Rueda’s objection to a three-level enhancement applied under U.S. Sentencing Guidelines § 3B1.1(b) for his supervisory role in the conspiracy because the stipulated facts support the enhancement. (Crim. Doc. 333 at ¶ 39; Crim. Doc. 491 at 6) The United States explained that, although Herrera-Rueda earnestly attempted to cooperate, his cooperation did not justify the filing of a substantial assistance motion.

(Crim. Doc. 491 at 8) Counsel highlighted Herrera-Rueda’s late entry into the conspiracy and cooperative efforts as mitigating circumstances that warranted a downward variance. (Id. at 10–11) Citing Herrera-Rueda’s attempt to cooperate with law enforcement, the district court varied downward from the guidelines range and

sentenced him to 204 months. (Id. at 22; Crim. Docs. 467 and 468) Herrera-Rueda filed no appeal. He now moves to vacate his conviction and sentence and claims retained counsel rendered constitutionally ineffective assistance during the plea proceedings and at sentencing. (Civ. Doc. 1) On May 30, 2025, the United States responded that Herrera-Rueda’s claims lack merit. (Civ. Doc. 5) An earlier order advises Herrera-Rueda that he could file a reply to the United States response within thirty days. (Civ. Doc. 2) To date, he has neither filed a reply nor sought an extension of time to do so.

II. Legal Standards Section 2255 allows a federal prisoner to “bring a collateral challenge by moving the sentencing court to vacate, set aside, or correct the sentence.” Winthrop-Redin v. United States, 767 F.3d 1210, 1215–16 (11th Cir. 2014). But “[o]nce the defendant’s

chance to appeal has been waived or exhausted, [a court is] entitled to presume he stands fairly and finally convicted, especially when . . . he already has had a fair opportunity to present his federal claims to a federal forum.” United States v. Frady, 456 U.S. 152, 164 (1982). “[A] collateral challenge, such as a § 2255 motion, may not be a surrogate for a direct appeal.” Lynn v. United States, 365 F.3d 1225, 1232 (11th Cir.

2004) (per curiam) (citing Frady, 456 U.S. at 165). Because collateral review is not a substitute for direct appeal, a defendant must raise on direct appeal all available claims. Relief under Section 2255 is reserved “for transgressions of constitutional rights and for that narrow compass of other injury that could not have been raised in direct appeal and would, if condoned, result in a complete miscarriage of justice.’ ” Richards v. United

States, 837 F.2d 965, 966 (11th Cir. 1988) (quoting United States v. Capua, 656 F.2d 1033, 1037 (5th Cir. Unit A Sep. 1981)). For example, a claim of ineffective assistance of counsel is a claim that “should usually be raised in a motion under 28 U.S.C. § 2255.” United States v. Curbelo, 726 F.3d 1260, 1267(11th Cir. 2013). “[T]he cases in which habeas petitioners can properly prevail on the ground of ineffective assistance of counsel are few and far between.” Waters v. Thomas, 46 F.3d 1506, 1511 (11th Cir. 1995) (en banc) (quoting Rogers v. Zant, 13 F.3d 384, 386 (11th

Cir. 1994)). As Sims v. Singletary, 155 F.3d 1297, 1305 (11th Cir. 1998), explains, Strickland v. Washington, 466 U.S. 668 (1984), governs an ineffective assistance of counsel claim: The law regarding ineffective assistance of counsel claims is well settled and well documented. In Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984), the Supreme Court set forth a two-part test for analyzing ineffective assistance of counsel claims. According to Strickland, first, the defendant must show that counsel’s performance was deficient. This requires showing that counsel made errors so serious that counsel was not functioning as the “counsel” guaranteed the defendant by the Sixth Amendment. Second, the defendant must show that the deficient performance prejudiced the defense. This requires showing that counsel’s errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable. Strickland, 466 U.S. at 687, 104 S. Ct. 2052.

Strickland requires proof of both deficient performance and consequent prejudice. Strickland, 466 U.S. at 697 (“There is no reason for a court deciding an ineffective assistance claim . . . to address both components of the inquiry if the defendant makes an insufficient showing on one.”); Sims, 155 F.3d at 1305 (“When applying Strickland, we are free to dispose of ineffectiveness claims on either of its two grounds.”). “[C]ounsel is strongly presumed to have rendered adequate assistance and made all significant decisions in the exercise of reasonable professional judgment.” Strickland, 466 U.S. at 690. “[A] court deciding an actual ineffectiveness claim must judge the reasonableness of counsel’s challenged conduct on the facts of the particular case, viewed as of the time of counsel’s conduct.” 466 U.S. at 690. Strickland requires that “in light of all the circumstances, the identified acts or omissions were outside the

wide range of professionally competent assistance.” 466 U.S. at 690.

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