Ibrahim v. Superintendent, Rappahannock Regional Jail

82 Va. Cir. 353, 2011 Va. Cir. LEXIS 56
CourtFairfax County Circuit Court
DecidedMarch 17, 2011
DocketCase No. CL-2010-16601
StatusPublished

This text of 82 Va. Cir. 353 (Ibrahim v. Superintendent, Rappahannock Regional Jail) is published on Counsel Stack Legal Research, covering Fairfax County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ibrahim v. Superintendent, Rappahannock Regional Jail, 82 Va. Cir. 353, 2011 Va. Cir. LEXIS 56 (Va. Super. Ct. 2011).

Opinion

By Judge Randy I. Bellows

On January 18, 2011, Respondent Superintendent of the Rappahannock Regional Jail filed a Demurrer to the Petitioner Adhem R. Ibrahim’s Petition for Writ of Habeas Corpus. The Court sent a letter to counsel on January 25, 2011, regarding responsive filings to the Demurrer. After reviewing the parties’ briefs, the Court is now prepared to rule.

I. Background

Mr. Ibrahim became a lawful permanent resident of the United States or a “green card holder” in 1992. He is not a full citizen of the United States.

On January 26, 2009, Mr. Ibrahim was charged with felony possession of marijuana with intent to distribute. Mr. Ibrahim pleaded [354]*354guilty to the misdemeanor offense of possession with intent to distribute marijuana on January 27, 2010, in the Fairfax County General District Court. The General District Court sentenced Mr. Ibrahim to ninety days in jail but suspended the entire active jail sentence.

Although Mr. Ibrahim was convicted of a misdemeanor, a drug trafficking crime involving marijuana is considered an “aggravated felony” under the Immigration and Nationality Act, and this offense made him subject to removal. See 8 U.S.C. § 1227(a)(2)(A)(iii) (“any alien who is convicted of an aggravated felony at any time after admission is deportable”); see also 8 U.S.C. § 1101(a)(43) (“[t]he term 'aggravated felony’ means ... illicit trafficking in a controlled substance (as defined in § 102 of the Controlled Substances Act [21 U.S.C. § 802]), including a drug trafficking crime (as defined in § 924(c) of title 18, United States Code)”). Mr. Ibrahim is currently being held pending removal proceedings in the Executive Office of Immigration Review.

Mr. Ibrahim filed his Notice and Petition for Writ of Habeas Corpus in this Court on November 23, 2010. Mr. Ibrahim argues that his trial counsel misadvised him of the immigration consequences of a guilty plea. Trial counsel candidly acknowledges this. Counsel “specifically told Mr. Ibrahim that in [his] opinion, as his attorney, he would suffer no adverse consequences to his immigration status as a result of this conviction.” (Affidavit of Trial Counsel, ¶ 3, Jan. 28, 2011.)

It appears that Respondent does not contest that trial counsel affirmatively misadvised Mr. Ibrahim. (Superintendent’s Reply to Petitioner’s Response to Demurrer 2, n. 2 (“In his first response, Petitioner states his understanding that the undersigned discussed the case with Petitioner’s criminal defense attorney. The undersigned did discuss the case with criminal defense counsel, who made a statement similar to the one set forth in the affidavit Petitioner has submitted. Accordingly, the Demurrer made no argument that Petitioner was given correct advice concerning the immigration consequences of his guilty plea.”) If, however, Respondent does contest this issue, the matter must be resolved at an evidentiary hearing.

Petitioner maintains that this affirmative misadvice constituted ineffective assistance of counsel under the standard outlined in Strickland v. Washington, 466 U.S. 668 (1984). Petitioner further argues that the ineffective assistance of his trial counsel rendered his plea unknowing and involuntary and, thereby, negated his guilty plea. See Gardner v. Warden, 222 Va. 491, 493, 281 S.E.2d 876, 877 (1981) (citing Boykin v. Alabama, 395 U.S. 238, 242, 89 S. Ct. 1709, 171, 23 L. Ed. 2d 274 (1969)); see also Va. Sup. Ct. R. 3A:8(b). Petitioner also notes that the case of Padilla v. Kentucky, 130 S. Ct. 1473, 1486 (2010), states “that counsel must inform her client whether his plea carries a risk of deportation.”

[355]*355In his Demurrer, Respondent argues that the writ of habeas corpus is an extraordinary remedy which is not appropriate in this case because Padilla announced a “new rule” that should not be applied retroactively to Mr. Ibrahim’s case. Teague v. Lane, 489 U.S. 288, 310 (1989). Respondent also argues that affirmative misinformation regarding the immigration consequences of a guilty plea did not constitute ineffective assistance prior to Padilla.

II. Analysis

A. Legal Standards

“The writ of habeas corpus ad subjiciendum shall be granted forthwith by the Supreme Court or any circuit court, to any person who shall apply for the same by petition, showing by affidavits or other evidence probable cause to believe that he is detained without lawful authority.” Va. Code Ann. § 8.01-654(A)(1). A petitioner may challenge the lawfulness of his detention if he alleges that he received ineffective assistance of counsel. iSfeeVa. Code Ann. § 8.01-654(B)(6). “It is well settled that a person.. .who seeks his release by habeas corpus on the grounds of ineffective assistance of counsel has the burden of proving the charge made by a preponderance of the evidence.” Peyton v. Ellyson, 207 Va. 423, 426 (1966).

An attorney has provided ineffective assistance to his client if (1) “counsel’s representation fell below an objective standard of reasonableness,” Strickland, 466 U.S. at 688, and (2) there is a “reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confidence in the outcome.” Id. at 698. In cases where the petitioner challenges a conviction based on a guilty plea, the petitioner must establish that, but for counsel’s error, he would not have pleaded guilty and “would have insisted on going to trial.” Hill v. Lockhart, 474 U.S. 52, 59 (1985); Lewis v. Warden, 274 Va. 93, 118, 645 S.E.2d 492, 506 (2007).

B. Findings

The questions posed by this case are (i) whether misadvice regarding immigration consequences of a guilty plea constituted ineffective assistance of counsel prior to the United States Supreme Court’s decision in Padilla-, (ii) if misadvice did not constitute ineffective assistance prior to Padilla, whether Padilla should be applied retroactively to this case; and (iii) whether Mr. Ibrahim is entitled to habeas relief based on the standard articulated in Strickland.

[356]*356Respondent contends that giving a client misinformation about the effect of a guilty plea on the client’s immigration status did not constitute ineffective assistance of counsel prior to Padilla. Based on its review of pertinent case law, the Court disagrees and finds that such misadvice constituted ineffective assistance of counsel.

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Related

Padilla v. Kentucky
559 U.S. 356 (Supreme Court, 2010)
Mills v. Green
159 U.S. 651 (Supreme Court, 1895)
Boykin v. Alabama
395 U.S. 238 (Supreme Court, 1969)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Teague v. Lane
489 U.S. 288 (Supreme Court, 1989)
Immigration & Naturalization Service v. St. Cyr
533 U.S. 289 (Supreme Court, 2001)
Gene C. Strader v. Sam Garrison, Warden
611 F.2d 61 (Fourth Circuit, 1979)
Philip James Ostrander v. Fred W. Green, Warden
46 F.3d 347 (Fourth Circuit, 1995)
United States v. Kwok Chee Kwan, AKA Jeff Kwan
407 F.3d 1005 (Ninth Circuit, 2005)
Carroll v. Johnson
685 S.E.2d 647 (Supreme Court of Virginia, 2009)
Lewis v. WARDEN OF FLUVANNA
645 S.E.2d 492 (Supreme Court of Virginia, 2007)
Zigta v. Commonwealth
562 S.E.2d 347 (Court of Appeals of Virginia, 2002)
Erie Insurance Group v. Hughes
393 S.E.2d 210 (Supreme Court of Virginia, 1990)
State v. Zarate
651 N.W.2d 215 (Nebraska Supreme Court, 2002)
Peyton v. Ellyson
150 S.E.2d 104 (Supreme Court of Virginia, 1966)
Laing v. Commonwealth
137 S.E.2d 896 (Supreme Court of Virginia, 1964)
Blair v. Peyton
171 S.E.2d 690 (Supreme Court of Virginia, 1970)
Blue Cross v. St. Mary's Hospital of Richmond, Inc.
426 S.E.2d 117 (Supreme Court of Virginia, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
82 Va. Cir. 353, 2011 Va. Cir. LEXIS 56, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ibrahim-v-superintendent-rappahannock-regional-jail-vaccfairfax-2011.