Juan Valdes v. United States of America

CourtDistrict Court, S.D. Florida
DecidedJuly 6, 2026
Docket1:25-cv-22495
StatusUnknown

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

Bluebook
Juan Valdes v. United States of America, (S.D. Fla. 2026).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 25-CV-22495-MOORE/Elfenbein

JUAN VALDES,

Petitioner,

v.

UNITED STATES OF AMERICA,

Respondent. _________________________________/

REPORT AND RECOMMENDATION

THIS CAUSE is before the Court on Petitioner Juan Valdes’s (“Petitioner”) Amended Petition for Writ of Error Coram Nobis (the “Amended Petition”), ECF No. [10]. Respondent, United States of America (“Respondent”), filed its Response to Juan Valdes’s Amended Petition for Writ of Error Coram Nobis to Vacate His Conviction (the “Response”), ECF No. [12], opposing the relief he seeks. Petitioner subsequently filed his Reply in Support of Coram Nobis Relief (the “Reply”), ECF No. [15]. The Honorable K. Michael Moore referred the above-captioned matter to me “to take all necessary and proper action as required by law regarding all pre-trial, non- dispositive matters and for a Report and Recommendation on any dispositive matters.” See ECF No. [16]. For the reasons explained below, I respectfully RECOMMEND that the Amended Petition, ECF No. [10], be DENIED. I. INTRODUCTION

A. Factual Background On September 30, 2014, Petitioner, a Cuban immigrant with lawful status, was arrested and charged on three counts relating to violation of the Federal Anti-kickback Statute. See United States v. Valdes, Case No. 14-CR-20712-KMM-6 (hereinafter “CR”) ECF No. [3] at 23; see also ECF No. [10-1] at ¶4. On November 10, 2014, he pleaded guilty to Count Two, conspiracy to violate a federal anti-kickback statute, 42 U.S.C. § 1320a-7(b)(1)(B), all in violation of 18 U.S.C. § 371.1 See CR ECF No. [99]; ECF No. [12-1] at 37:8-11. Petitioner was sentenced to 24 months

in prison followed by a three-year term of supervised release. See CR ECF No. [188] at 2-3; see also CR ECF No. [237] at 4:25-5:21. Petitioner commenced his prison sentence on February 3, 2015 and thereafter commenced his term of supervised release on October 21, 2016. See CR ECF No. [210] at 6; see also CR ECF No. [237] at 4:25-5:21; CR ECF No. [235] at 1. After his release life seemingly returned to normal, until he attempted to apply for a green card in or around February 2025. See ECF No. [10-1] at ¶¶16-19. He now asserts that February 2025 is the first time he learned that the guilty plea he entered into a decade earlier carried deportation consequences requiring mandatory removal. See id. at ¶¶19, 22-24. B. Procedural History 1. The Petition for Writ of Error Coram Nobis

Against this factual backdrop, Petitioner filed a Petition for Writ of Error Coram Nobis (the “Original Petition”) under 28 U.S.C. § 1651(a) (the All Writs Act) requesting the Court vacate his decade-old conviction on grounds of ineffective assistance of counsel. See generally ECF No. [1]. Much like the Amended Petition, Petitioner filed the Original Petition arguing that his former counsel committed ineffective assistance of counsel when he failed to warn Petitioner of the immigration consequences associated with entering into a guilty plea, including deportation. See generally ECF No. [1]. The Original Petition explained that counsel misguided Petitioner during the criminal case when counsel told Petitioner that accepting a guilty plea would be the only way

1 In the plea agreement, the Government agreed to dismiss the remaining counts at sentencing. See CR ECF No. [94] at ¶1. certain to avoid immigration consequences. See id. at ¶¶5-12. Petitioner insisted that he had no reason to question counsel’s advice and that counsel never advised Petitioner to consult with an immigration attorney before pleading guilty. See id. at ¶13. For Petitioner, remaining in the United States with his family was of paramount importance and he claims to have made this clear to

counsel. See id. at ¶16. In the Original Petition, Petitioner explains that he would not have accepted the plea had he known doing so would ensure his deportation and vanquish any chance at gaining status in the United States. See id. at ¶19. The Honorable K. Michael Moore dismissed the Original Petition without prejudice because, inter alia, it “largely ignored” the record and failed to address any potential implications addressed in the plea agreement, Report and Recommendation regarding the plea agreement, the presentence investigation report, the special conditions of supervised release, and the sentencing hearing. See ECF No. [6] at 3-6. 2. The Amended Petition for Writ of Error Coram Nobis Following the dismissal of the Original Petition, Petitioner filed the Amended Petition, arguing that he is entitled to relief because his counsel in the underlying criminal case, Sky Elliot

Smith (“Mr. Smith”), provided constitutionally ineffective assistance of counsel when he2 downplayed the immigration consequences associated with pleading guilty. See ECF No. [10] at 3, 16, 19. Petitioner first accuses Mr. Smith of providing false information and assurances that pleading guilty would avoid immigration consequences. See id. He argues that Mr. Smith had a duty to advise him that deportation was mandatory under the Immigration and Nationality Act (“INA”) because Petitioner pleaded guilty to an aggravated felony and the consequence for doing so under the statute was mandatory removal. See id. at 14-15. According to Petitioner, he did not

2 In the Amended Petition, Petitioner incorrectly describes Mr. Smith as an Assistant Federal Public Defender, when he, in fact, was private counsel appointed under the Criminal Justice Act. See CR ECF No. [59]. knowingly and voluntarily plead guilty because of his misunderstanding of immigration law. See ECF No. [10] at 8. Because of this, Petitioner argues that Mr. Smith’s incorrect advice and Petitioner’s misunderstanding of the law colored his acknowledgements that he understood the plea agreement. See id. at 17. He also argues that the plea agreement’s language was equivocal

and too generic to truly highlight the grave immigration consequences implicated by pleading guilty here, and that other courts have rejected the same plea language for those reasons. See id. at 14-15. Next, Petitioner argues that the Court’s questions and explanations during the change of plea colloquy did not cure Mr. Smith’s purportedly deficient performance because they too were equivocal, generic, and did not reflect the immigration consequences specific to Petitioner’s case. See id. at 14-15, 17. The Court’s findings in the Report and Recommendation in the underlying criminal case similarly do not cure ineffective assistance of counsel because Petitioner was operating under Mr. Smith’s misguidance. See id. at 16-17. Petitioner insists that, during the plea colloquy, the Court moved through the boiler-plate script and did not inquire whether Petitioner

received immigration advice, nor did it attempt to ensure that his understanding of these circumstances was correct. See id. According to Petitioner, Mr. Smith’s failure to object on the record is irrelevant to the ineffective assistance of counsel analysis because, inter alia, Petitioner failed to recognize that Mr. Smith’s misstatements of law led to a series of “inefficacies in the record.” See id. Third, Petitioner argues that the prejudice prong of the ineffective assistance of counsel analysis is satisfied here because he has shown a reasonable probability that but for Mr.

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