Hurtado v. United States

CourtDistrict Court, D. Nevada
DecidedMarch 31, 2020
Docket2:17-cv-00761
StatusUnknown

This text of Hurtado v. United States (Hurtado 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
Hurtado v. United States, (D. Nev. 2020).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 DISTRICT OF NEVADA 6 * * *

7 UNITED STATES OF AMERICA, Case No. 2:08-cr-00102-KJD 2:17-cv-0761-KJD 8 Respondent, ORDER 9 v.

10 ENRIQUE HURTADO,

11 Petitioner.

12 Presently before the Court is Petitioner Enrique Hurtado’s (“Petitioner”) Motion to 13 Vacate, Set Aside, or Correct Sentence Pursuant to 28 U.S.C. § 2255 (“2255 Motion”) (#85). 14 The Government filed responses and supplements in opposition (#87/91) to which Petitioner 15 replied (#89). All other pending motions are denied as moot. 16 I. BACKGROUND 17 On August 13, 2008, Petitioner was found guilty at trial of all eleven counts of the 18 indictment. On January 5, 2009, the Court entered Judgment against Defendant on those counts: 19 Count 1 – Armed Bank Robbery 20 Counts 2 & 4 – Use of a Firearm During and in Relation to a 21 Crime of Violence 22 Count 3 – Interference with Commerce by Armed Robbery 23 Counts 5, 6, 7, & 8 – Interference with Commerce by Robbery 24 Count 9 – Interference with Commerce by Attempted Robbery 25 Count 10 – Bank Robbery 26 Count 11 – Deported Alien Found Unlawfully in the United States 27 Defendant received a cumulative sentence of five hundred thirty-four (534) months. 28 1 On June 23, 2016, Petitioner filed an abridged 2255 motion, followed by a 2 comprehensive 2255 motion, after receiving permission from the court of appeals to file a second 3 or successive motion, on March 16, 2017, arguing that his sentence violates due process because 4 it is based on an unconstitutionally vague portion of 18 U.S.C. § 924(c). Petitioner's vagueness 5 argument relies on Johnson v. United States, 135 S. Ct. 2551 (2015). In Johnson, the U.S. 6 Supreme Court ruled that the residual clause of the Armed Career Criminal Act (ACCA) is 7 unconstitutionally vague. Johnson, 135 S. Ct. at 2557. Petitioner accordingly points to language 8 in § 924(c)'s residual clause, which is identical to that of the ACCA's residual clause, for the 9 proposition that both provisions, and any convictions and sentences arising therefrom, are 10 invalid. 11 After the ruling in Johnson, the Ninth Circuit issued its decision in United States v. 12 Blackstone, 903 F.3d 1020, 1028–29 (9th Cir. 2018), cert. denied, 139 S. Ct. 2762 (2019). As 13 pertinent to this case, the Ninth Circuit held that Johnson had not been extended to sentences 14 imposed pursuant to § 924(c). Id. at 1028. Consequently, a 2255 motion seeking to invalidate a § 15 924 conviction based on Johnson, would therefore be untimely. Id. at 1028, 1029 (“The Supreme 16 Court may hold in the future that Johnson extends to sentences imposed ... pursuant to [§ 924(c)], 17 but until then [the petitioner's] motion is untimely.”). 18 II. Legal Standard 19 Under 28 U.S.C. § 2255, a petitioner may file a motion requesting the Court which 20 imposed sentence to vacate, set aside, or correct the sentence. 28 U.S.C. § 2255(a). Such a 21 motion may be brought on the following grounds: “(1) the sentence was imposed in violation of 22 the Constitution or laws of the United States; (2) the court was without jurisdiction to impose the 23 sentence; (3) the sentence was in excess of the maximum authorized by law; or (4) the sentence 24 is otherwise subject to collateral attack.” Id.; see United States v. Berry, 624 F.3d 1031, 1038 25 (9th Cir. 2010). When a petitioner seeks relief pursuant to a right newly recognized by a decision 26 of the United States Supreme Court, a one-year statute of limitations applies. 28 U.S.C. § 27 2255(f)(3). That one-year limitation begins to run from “the date on which the right asserted was 28 initially recognized by the Supreme Court.” Id. § 2255(f)(3). 1 III. Analysis 2 Petitioner argues that his convictions for Armed Bank Robbery and Hobbs Act Robbery 3 are not qualifying predicate crimes of violence. Title 18 United States Code Section 924(c) 4 criminalizes the use or carrying of a firearm in relation to a “crime of violence,” and it imposes 5 mandatory minimum sentences that must run consecutive to any other sentence. An offense may 6 qualify as a crime of violence under § 924(c) through either of two clauses: § 924(c)(3)(A) or § 7 924(c)(3)(B). Section 924(c)(3)(A), also known as the statute's “force clause,” applies if an 8 individual is convicted of a predicate crime that “has as an element the use, attempted use, or 9 threatened use of physical force against the person or property of another.” By contrast, § 10 924(c)(3)(B), known as the “residual clause” of the statute, is much broader; it applies if the 11 individual is convicted of any predicate felony offense “that by its nature, involves a substantial 12 risk that physical force against the person or property of another may be used in the course of 13 committing the offense.” The U.S. Supreme Court recently invalidated § 924(c)(3)(B) after 14 holding that its language is unconstitutionally vague. See United States v. Davis, 139 S. Ct. 15 2319, 2335–36 (2019). However, the force clause, § 924(c)(3)(A), has not been deemed 16 unconstitutional. 17 A. Armed Bank Robbery 18 Here, Petitioner argues that his sentence based on the underlying armed bank robbery and 19 Hobbs Act Robbery convictions violate due process because the Court imposed them under the 20 unconstitutionally vague residual clause, 18 U.S.C. § 924(c)(3)(B). To make that argument, 21 Petitioner points to his predicate offense of Armed Bank Robbery in violation of 18 U.S.C. § 22 2113. He claims that Armed Bank Robbery is not a crime of violence by its elements, and thus 23 his sentence enhancement for that predicate crime under Section 924(c) must have arisen from 24 the unconstitutional residual clause. The Ninth Circuit in United States v. Watson, 881 F.3d 782 25 (9th Cir.), cert. denied, 139 S. Ct. 203 (2018), rejected the same arguments made by Petitioner 26 when it held that federal armed bank robbery constitutes a crime of violence by its elements. 881 27 F.3d at 786. Petitioner's conviction for Armed Bank Robbery therefore implicates the force 28 clause, 18 U.S.C. § 924(c)(3)(A), not the unconstitutional residual clause—rendering Petitioner 1 ineligible for relief on the grounds argued in his 2255 motion. Accordingly, the Court denies 2 Petitioner’s § 2255 motions. 3 B. Hobbs Act Robbery 4 Further, the Court finds that Petitioner’s claims that Hobbs Act Robbery cannot be a 5 qualifying crime of violence must be dismissed. Hurtado argues that a Hobbs Act Robbery 6 cannot categorically fall under the force or elements clause of § 924(c)(3)(A) because a Hobbs 7 Act Robbery can be committed by any amount of force necessary to accomplish the taking, it 8 does not necessarily require the use of violent force. Prior to the Supreme Court's holding in 9 Davis, the Ninth Circuit held that Hobbs Act “[r]obbery indisputably qualifies as a crime of 10 violence” under § 924(c). United States v.

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