Johnathon Irish v. United States of America

2017 DNH 217
CourtDistrict Court, D. New Hampshire
DecidedOctober 19, 2017
Docket16-cv-70-PB
StatusPublished

This text of 2017 DNH 217 (Johnathon Irish v. United States of America) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Johnathon Irish v. United States of America, 2017 DNH 217 (D.N.H. 2017).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Johnathon Irish

v. Case No. 16-cv-70-PB Opinion No. 2017 DNH 217 United States of America

MEMORANDUM AND ORDER

Johnathon Irish was charged in a five-count Indictment,

which included charges of Aiding and Abetting the Making of a

Material False Statement in Connection with the Acquisition of a

Firearm (Count One), in violation of 18 U.S.C. § 922(a)(6),

and Making a Material False Statement to a Federal Agent (Count

Two), in violation of 18 U.S.C. § 1001. Three additional counts

were later dismissed without prejudice on the government’s

motion.1 Irish ultimately entered into a plea agreement to

resolve Counts One and Two on the eve of trial. The government

agreed in the plea agreement not to seek charges against Irish

based on the conduct described in the dismissed counts. It also

agreed that Irish should receive a below guideline, 18-month

1 The remaining charges included a second count of Making a Material False Statement to a Federal Agent (Count Three), Engaging in the Business of Dealing Firearms Without a Federal Firearms License (Count Four), and Possession of a Firearm as a Regular User of a Controlled Substance (Count Five). prison sentence. Irish received the sentence called for in the

plea agreement on February 19, 2015, which amounted to time

served at that point. He was released on supervised release the

next day.

Irish has now filed a motion pursuant to 28 U.S.C. § 2255

arguing that his guilty pleas must be set aside. His principal

claim is that his pleas were tainted by his counsels’

constitutionally ineffective legal assistance. Irish was

represented by Attorneys Lawrence Vogelman and Kirk Simoneau

both at the time he pleaded guilty and during most of the pre-

trial period. Irish contends that his counsels’ representation

was both objectively inadequate and improperly affected by an

alleged conflict of interest. He also contends that he was

improperly coerced into pleading guilty by the government’s

threats to charge his wife if he did not accept the plea

agreement. I address and reject each argument in turn, and deny

Irish’s motion for the reasons that follow.

I. Ineffective Assistance of Counsel

A. Inadequate Representation

A defendant has a constitutional right to the effective

assistance of counsel at every critical stage of a criminal

proceeding. Lee v. United States, 137 S. Ct. 1958, 1964 (2017).

2 To establish an ineffective assistance of counsel claim, a

petitioner must prove both “deficient performance by counsel and

resulting prejudice.” Peralta v. United States, 597 F.3d 74, 79

(1st Cir. 2010) (citing Strickland v. Washington, 466 U.S. 668,

692 (1984)).

The “deficient performance” prong of this standard requires

proof that trial counsel’s representation fell below “an

objective standard of reasonableness,” Pina v. Maloney, 565 F.3d

48, 54-55 (1st Cir. 2009), as measured “under prevailing

professional norms.” Strickland, 466 U.S. at 688. “This is a

highly deferential review, ‘making every effort to eliminate the

distorting effects of hindsight.’” Sleeper v. Spencer, 510 F.3d

32, 38 (1st Cir. 2007) (quoting Strickland, 466 U.S. at 689).

Accordingly, counsel has “wide latitude in deciding how best to

represent a client,” Yarborough v. Gentry, 540 U.S. 1, 5–6

(2003), and those decisions are entitled to a strong presumption

that counsel has rendered adequate assistance and exercised

reasonable professional judgment. Strickland, 466 U.S. at 690;

see United States v. Dunfee, 821 F.3d 120, 128 (1st Cir. 2016).

When challenging representation preceding a guilty plea,

the “prejudice” prong can be satisfied “by demonstrating a

‘reasonable probability that, but for counsel’s errors, [the

petitioner] would not have pleaded guilty and would have

3 insisted on going to trial.’” Lee, 137 S. Ct. at 1965 (quoting

Hill v. Lockhart, 474 U.S. 52, 59 (1985)). In undertaking this

analysis, “courts should not upset a plea solely because of post

hoc assertions from a defendant about how he would have pleaded

but for his attorney’s deficiencies.” Id. at 1967. Instead, a

judge must “look to contemporaneous evidence to substantiate a

defendant’s expressed preferences.” Id.

Irish first claims that Attorneys Vogelman and Simoneau

conducted an inadequate investigation and gave him bad advice to

plead guilty.2 In particular, he faults counsel for (i) failing

to properly evaluate and advise him with respect to a possible

government misconduct defense;3 (ii) failing to prepare an

effective cross-examination of Irish’s wife, who was scheduled

to be a government witness; and (iii) failing to advise Irish

that he could defend against the false statement charges because

2 Irish also argues that counsel both improperly threatened to withdraw on the eve of trial if he did not plead guilty, and instructed him to provide false testimony during the guilty plea colloquy. I reject these arguments because I am unpersuaded by the evidence Irish cites to support them.

3 Irish claims that he was the victim of a vindictive prosecution. To the extent that he faults counsel for also failing to investigate and advise him on a possible entrapment defense or a possible motion to dismiss based on the government’s submission of perjured testimony to the grand jury, his arguments fail because the record does not support a claim that counsel was ineffective for failing to pursue either issue.

4 the underlying statements were both immaterial and outside the

jurisdictional scope of 18 U.S.C. § 1001.

For the reasons stated herein, I conclude that Irish has

failed to satisfy either the “deficient performance” or

“prejudice” prong of the Strickland standard.

1. Deficient Performance

Vogelman’s and Simoneau’s representation of Irish was not

objectively unreasonable under prevailing professional norms. I

address each alleged error in turn.

Irish’s primary claim is that he was the victim of

vindictive prosecution and his counsel was deficient in

neglecting to pursue or advise him of a potential government-

misconduct defense under that theory. The alleged basis for

this unpursued defense is Irish’s claim that the FBI

investigation that eventuated in his indictment was itself

retaliatory, and the charges against him were therefore the

product of a government conspiracy. Irish maintains that the

FBI’s investigation was initiated after he had previously

demanded the termination of a New Hampshire DCYF official

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Related

Peralta v. United States
597 F.3d 74 (First Circuit, 2010)
United States v. Rodgers
466 U.S. 475 (Supreme Court, 1984)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Yarborough v. Gentry
540 U.S. 1 (Supreme Court, 2003)
Bucuvalas v. United States
98 F.3d 652 (First Circuit, 1996)
United States v. Sebaggala
256 F.3d 59 (First Circuit, 2001)
United States v. Colon-Torres
382 F.3d 76 (First Circuit, 2004)
United States v. Mescual-Cruz
387 F.3d 1 (First Circuit, 2004)
Sleeper v. Spencer
510 F.3d 32 (First Circuit, 2007)
Pina v. Maloney
565 F.3d 48 (First Circuit, 2009)
United States v. Bucci
582 F.3d 108 (First Circuit, 2009)
United States v. Raul Rivera Ramos, A/K/A Raulito
856 F.2d 420 (First Circuit, 1988)
United States v. Roberto MacEo
873 F.2d 1 (First Circuit, 1989)
Jesus Geles Valencia v. United States
923 F.2d 917 (First Circuit, 1991)
Oyague v. Artuz
274 F. Supp. 2d 251 (E.D. New York, 2003)
United States v. Mehanna
735 F.3d 32 (First Circuit, 2013)
United States v. Dunfee
821 F.3d 120 (First Circuit, 2016)

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