Rocha-Alonso v. United States

CourtDistrict Court, D. New Mexico
DecidedAugust 6, 2025
Docket2:23-cv-00906
StatusUnknown

This text of Rocha-Alonso v. United States (Rocha-Alonso v. United States) is published on Counsel Stack Legal Research, covering District Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rocha-Alonso v. United States, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

JAVIER ROCHA-ALONSO,

Petitioner,

v. No. 23-cv-906 MIS-SCY No. 22-cr-1568 MIS-SCY UNITED STATES OF AMERICA,

Respondent.

ORDER VACATING IN PART ORDER OF REFERENCE, DENYING IN PART MOTION UNDER 28 U.S.C. § 2255 TO VACATE, SET ASIDE, OR CORRECT SENTENCE, GRANTING MOTION TO APPOINT COUNSEL, AND REFERRING REMAINING ISSUE TO MAGISTRATE JUDGE

THIS MATTER is before the Court on Petitioner Javier Rocha-Alonso’s Motion Under 28 U.S.C. § 2255 to Vacate, Set Aside, or Correct Sentence (CV Doc. 1, CR Doc. 21).1 Petitioner is a federal prisoner proceeding pro se. He alleges due process violations in his deportation proceedings and ineffective assistance of counsel in both his criminal case and in the revocation of his supervised release in a separate but related criminal matter. Having reviewed the parties’ submissions and the record, the Court will deny all of Petitioner’s grounds for relief, except for the claim that his counsel was ineffective for failing to file an appeal. This limited issue must be resolved following an evidentiary hearing. Counsel will be appointed to represent Petitioner at the hearing.

1 On November 12, 2024, the Court issued an Order of Reference referring this case to Magistrate Judge Steven C. Yarbrough “to conduct hearings, if warranted, including evidentiary hearings, and to perform any legal analysis required to recommend to the Court an ultimate disposition of the case.” ECF No. 18. That Order is hereby VACATED IN PART and solely with respect to the issues disposed of by this Order. For clarity, the Court will refer the sole remaining issue to Judge Yarbrough in this Order’s “Conclusion” Section. BACKGROUND On March 12, 2021, Petitioner was charged with one count of Reentry of a Removed Alien in violation of 8 U.S.C. §§ 1326(a) and (b). United States v. Rocha-Alonso, Case No. 2:21-CR-606-MIS (hereinafter “Rocha-Alonso I”). He was previously removed from the United States on January 24, 2020. Id. at CR Doc. 13 (Information). Petitioner pleaded guilty pursuant

to a plea agreement and was sentenced on October 4, 2021 to 18 months of imprisonment and 2 years’ supervised release. Id. at CR Docs. 16 (Plea Agreement), 24 (Judgment). On June 21, 2022, Petitioner was deported from the United States after having served his custody sentence. Id. at CR Doc. 28. Approximately two weeks later, he violated the terms of his release by unlawfully reentering the United States. Id. A petition was filed to revoke his supervised release. Id. On July 7, 2022, the underlying criminal case was filed, charging Petitioner with Reentry of a Removed Alien in violation of 8 U.S.C. §§ 1326(a) and (b). United States v. Rocha-Alonso, Case No. 2:22-CR-1568-MIS (hereinafter “Rocha-Alonso II”). On September 22, 2022, Petitioner pleaded guilty pursuant to a Rule 11(c)(1)(C) “Fast Track Plea Agreement,” which

stipulated to a two-level downward departure in accordance with the United States Sentencing Guidelines (USSG) § 5K3.1 as long as he was not found to be within a criminal history category of VI. Id. at CR Doc. 14 (Plea Agreement). Petitioner agreed to an appellate waiver within the plea agreement. Id. at 6. At the change of plea hearing, Petitioner was represented by attorney David Benatar. On October 27, 2022, a presentence investigation report (PSR) was submitted to the Court in Rocha-Alonso II. (CR Doc. 16). The PSR identified four criminal cases, filed between 2012 to 2016, in which Petitioner was charged and convicted with Reentry of a Removed Alien. Id. 2 The PSR calculated his total offense level at 10, with a criminal history category of VI. Id. On February 1, 2023, the Court held a sentencing hearing on both the supervised release violation in Rocha-Alonso I and the Reentry of a Removed Alien charge in Rocha-Alonso II. Mr. Benatar appeared as counsel for Petitioner on both matters and was present at the sentencing hearing. See Rocha-Alonso I, CR Doc. 41 at 3. Petitioner was sentenced to 21 months of

imprisonment for violating the mandatory terms of his supervised release, and 30 months’ imprisonment for Reentry of a Removed Alien, with the sentences to run consecutively for a total of 51 months’ imprisonment. Id. at 11-13. The Court rejected the two-level downward reduction in the plea agreement due to his criminal history category of VI. Id. at 12. Petitioner now seeks to vacate his conviction and sentence. The Motion raises four grounds for relief, although the last two appear duplicative: (Claim 1) Denial of due process in his deportation proceedings and failure of counsel to challenge those proceedings; (Claim 2) Ineffective assistance of counsel for failure to file a notice of appeal, argue for his sentences to run concurrently, and seek downward departures; and

(Claims 3 and 4) Guilty plea was not made knowingly, intelligently, and voluntarily because the plea agreement was not explained to him, and he was denied access to counsel before and during his plea hearing. The United States filed an answer to the Motion with supporting supplemental materials (CV Doc. 9), and Petitioner filed a reply (CV Doc. 16). DISCUSSION A petition under 28 U.S.C. § 2255 attacks the legality of a federal prisoner’s detention. Bradshaw v. Story, 86 F.3d 164, 166 (10th Cir. 1996). A district court may grant relief under 3 § 2255 if it determines that “the judgment was rendered without jurisdiction, or that the sentence imposed was not authorized by law or otherwise open to collateral attack, or that there has been such a denial or infringement of the constitutional rights of the prisoner as to render the judgment vulnerable to collateral attack.” 28 U.S.C. § 2255. Because Petitioner is proceeding pro se, the Court will liberally construe his pleadings.

See Haines v. Kerner, 404 U.S. 519 (1972). This broad reading of a pro se litigant’s pleadings does not, however, relieve him of the burden of alleging sufficient facts upon which a legal claim may be based. Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991). Relief is available where “the sentence was imposed in violation of the Constitution or laws of the United States,” including the Sixth Amendment right to effective counsel. 28 U.S.C. § 2255(a). See also United States v. Tucker, 745 F.3d 1054, 1066 (10th Cir. 2014) (“Sixth Amendment claims asserting ineffective assistance of counsel can and generally must be brought in a habeas action for post-conviction relief under 28 U.S.C. § 2255.”). A successful ineffective assistance of counsel claim must meet the two-prong test set forth in Strickland v. Washington, 466 U.S. 668, 687 (1984). First, the petitioner must show “[c]ounsel’s performance was

deficient” and contained “errors so serious that counsel was not functioning as the ‘counsel’ guaranteed the defendant by the Sixth Amendment.” Id. at 688.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Carlos Alvarez
184 F. App'x 876 (Eleventh Circuit, 2006)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
United States v. Booker
543 U.S. 220 (Supreme Court, 2004)
United States v. Adame-Orozco
607 F.3d 647 (Tenth Circuit, 2010)
United States v. Arita-Campos
607 F.3d 487 (Seventh Circuit, 2010)
Bradshaw v. Story
86 F.3d 164 (Tenth Circuit, 1996)
Battenfield v. Gibson
236 F.3d 1215 (Tenth Circuit, 2001)
United States v. Cockerham
237 F.3d 1179 (Tenth Circuit, 2001)
United States v. Hahn
359 F.3d 1315 (Tenth Circuit, 2004)
United States v. Garrett
402 F.3d 1262 (Tenth Circuit, 2005)
United States v. Silva
430 F.3d 1096 (Tenth Circuit, 2005)
United States v. Chavez-Alonso
431 F.3d 726 (Tenth Circuit, 2005)
United States v. Palermo
175 F. App'x 244 (Tenth Circuit, 2006)
Sperry v. McKune
445 F.3d 1268 (Tenth Circuit, 2006)
United States v. Sandoval
477 F.3d 1204 (Tenth Circuit, 2007)
The United States of America v. Eddie Barboa
777 F.2d 1420 (Tenth Circuit, 1985)
United States v. Robert Estrada, Jr.
849 F.2d 1304 (Tenth Circuit, 1988)
United States v. James Sam Marr
856 F.2d 1471 (Tenth Circuit, 1988)

Cite This Page — Counsel Stack

Bluebook (online)
Rocha-Alonso v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rocha-alonso-v-united-states-nmd-2025.