Morillo v. United States

CourtDistrict Court, D. New Hampshire
DecidedNovember 30, 2020
Docket1:20-cv-00164
StatusUnknown

This text of Morillo v. United States (Morillo v. United States) 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
Morillo v. United States, (D.N.H. 2020).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Franklyn Morillo

v. Case No. 20-cv-164-SM Opinion No. 2020 DNH 207 United States of America

ORDER

Petitioner providently pled guilty to participating in a drug distribution conspiracy. He and his wife operated a substantial drug distribution business from their home in Haverhill, Massachusetts. His plea was offered under a written agreement with the government in which the parties stipulated (Fed. R. Cr. P. 11(c)(1)(C)) that the Guidelines calculation in his case would start with a base offense level of not less than 26 nor more than 30, depending on the drug weight attributable to Petitioner.

The pre-sentence investigation report conservatively estimated the attributable drug weight and the court determined that the correct base offense level was 30, within the range stipulated. Petitioner was sentenced, inter alia, to 168 months in prison, a sentence at the low end of the applicable Guidelines range. Petitioner appealed his sentence, seeking to challenge enhancements under the Guidelines, as well as some supervised release conditions imposed. The appeal was deemed barred by the waiver provisions included in his written agreement with the government. United States v. Morillo, 910 F.3d 1 (1st Cir. 2018).

Petitioner now seeks similar relief, under 28 U.S.C. § 2255, on an ineffective assistance of counsel theory. He argues that defense counsel 1) should have challenged the drug weight attributable to him, as well as the leadership enhancement and a premises or “stash house” enhancement, at sentencing; 2) incorrectly advised him that he could be responsible for all drugs involved in the conspiracy rather than just those reasonably foreseeable to him; 3) failed to advise him of his right to testify at sentencing, which he claims he would have exercised; 4) failed to challenge conditions of supervised release imposed; and, 5) generally failed to advise him that he

could plead guilty with no plea agreement and did not adequately discuss the advantages and disadvantages of proceeding to trial rather than pleading guilty.

Petitioner’s Burden - Ineffective Assistance To prevail on an ineffective assistance of counsel claim, a petitioner must show two things: First, that counsel’s representation fell below an objective threshold of reasonable care, and second, that he was prejudiced by that deficient performance. See Strickland v. Washington, 466 U.S. 668, 687 (1984). The prejudice test is met only if Petitioner shows that there is a reasonable probability that the outcome of the

proceedings would have been different but for counsel’s deficient representation. Id.

In this case, Petitioner also seems to challenge the providence of his guilty plea, saying he would not have pled guilty if he had been advised by counsel of the advantages and disadvantages of going to trial, or if he had been properly advised that he would be held accountable under the Guidelines only for those drug quantities involved in the conspiracy that were reasonably foreseeable to him (instead of the full amount). He further says that he would have negotiated an agreement that did not include a waiver of his appellate rights had he been

told of that option. To the extent Petitioner challenges his guilty plea, in order to meet the Strickland prejudice test, he must demonstrate “a reasonable probability that but for counsel’s errors, he would not have pled guilty and would have insisted on going to trial.” Hill v. Lockhart, 474 U.S. 52, 59 (1984). Discussion Failure to Contest the Attributable Drug Quantities Defense counsel’s acceptance of the drug quantities estimated by the probation officer - and communicated in the presentence investigation report, was not only reasonable and

well within the bounds of adequate representation, but, had counsel “put the government to its proof,” as Petitioner claims he should have done, that would have likely qualified as ineffective assistance. It cannot be rationally disputed that the evidence would easily have supported a much higher estimate of drug quantities reasonably foreseeable to Petitioner. That evidence included Petitioner’s own statements to police, and, those captured on wiretaps, as well as the testimony of co- conspirators. Petitioner was held accountable for only one year of drug dealing, when he himself admitted that he had been dealing for years, and, the attributed quantities during that year were substantially less than quantities he himself had

acknowledged.

Had defense counsel made an issue of it, the government would have been given the opportunity to present that evidence and the resulting offense level would have been higher. Without question, Petitioner would have lost the benefit of his plea bargain, and would have been facing greater exposure to a much longer sentence, which he likely would have received. Counsel’s decision was wise, and, certainly no prejudice can be shown, given the predictable adverse results for Petitioner had counsel not accepted the conservative quantity estimates.

The Enhancements for Role in the Offense and Premises Use (“stash house”)

Defense counsel objected to each enhancement based on the undisputed evidence and made appropriate legal arguments supporting his objections. That his objections were not sustained does not alter the fact that his representation fell well within the bounds of reasonable and competent representation. Petitioner’s claims that counsel should have done more (call witnesses, call the Petitioner, etc.) are unaccompanied by any proffer that would undermine in any way the rulings on those enhancements. The record is clear and supports both enhancements, and counsel vigorously and appropriately challenged their imposition, within the bounds of reasonable representation. Counsel was not ineffective in that regard, and Petitioner cannot show prejudice, as he cannot demonstrate a reasonable probability that but for counsel’s actions the outcome would have been different. Failure to Properly Advise of Right to Testify at Sentencing; Properly Advise About Drug Quantity Attribution; to Properly Advise of Possible Guilty Plea Without an Agreement Containing a Waiver of Appellate Rights or of the Advantages or Disadvantages of Going to Trial Rather Than Plead Guilty; and, Failure to Call Mitigation Witnesses

Petitioner asserts that defense counsel did not advise him of his right to testify at sentencing. Had counsel so advised, he says he would have exercised his right and testified in opposition to the drug weights ascribed to him, the enhancement for using his home to deal drugs, and the enhancement for his supervisory role in the distribution conspiracy.

“A criminal defendant’s right to testify on his own behalf – or, conversely, not to testify – is a critically important right. Given the salience of the right, a defendant is entitled to be fully briefed so that he may make an informed choice.” Casiano-Jimenez v. United States, 817 F. 3d 816, 818 (1st Cir. 2016). Crediting Petitioner’s assertions as true for the purposes of resolving this issue, counsel’s failure to advise Petitioner of both his right to testify and his right to make the choice between testifying or not, would constitute ineffective assistance.1

1 Obviously, no finding of fact is made in that regard as no hearing, at which defense counsel would have the opportunity to challenge the assertion of fact has been held.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Casiano-Jimenez v. United States
817 F.3d 816 (First Circuit, 2016)
Jae Lee v. United States
582 U.S. 357 (Supreme Court, 2017)
United States v. Morillo
910 F.3d 1 (First Circuit, 2018)
Franklyn Morillo v. United States of America
2020 DNH 207 (D. New Hampshire, 2020)

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Bluebook (online)
Morillo v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/morillo-v-united-states-nhd-2020.