Rodriguez-Mendez v. United States

134 F.4th 1
CourtCourt of Appeals for the First Circuit
DecidedApril 8, 2025
Docket20-1360
StatusPublished

This text of 134 F.4th 1 (Rodriguez-Mendez v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rodriguez-Mendez v. United States, 134 F.4th 1 (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

No. 20-1360

JULIO A. RODRÍGUEZ-MÉNDEZ,

Petitioner, Appellant,

v.

UNITED STATES,

Respondent, Appellee.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

[Hon. Gustavo A. Gelpí, U.S. District Judge]

Before

Barron, Chief Judge, Montecalvo and Aframe, Circuit Judges.

Kevin E. Lerman, Assistant Federal Public Defender with whom Rachel Brill, Federal Public Defender, District of Puerto Rico, Héctor L. Ramos-Vega, Interim Federal Public Defender, District of Puerto Rico, and Franco L. Pérez-Redondo, Assistant Federal Public Defender, Supervisor, Appeals Division, were on brief, for Appellant. Michael A. Rotker, with whom, W. Stephen Muldrow, United States Attorney, Mariana E. Bauzá-Almonte, Assistant United States Attorney, Chief, Appellate Division, and Ricardo A. Imbert-Fernández, Assistant United States Attorney, were on brief, for Appellee.

April 8, 2025 AFRAME, Circuit Judge. This is an appeal from the

district court's denial of Julio Rodríguez-Méndez's ("Rodríguez")

motion under 28 U.S.C. § 2255. In his motion, Rodríguez sought

relief from (1) his conviction for felon-in-possession of a

firearm under 18 U.S.C. § 922(g)(1) on double jeopardy grounds and

(2) his sentence for that offense, which was based on the

sentencing court's conclusion that he was an armed career criminal

under 18 U.S.C. § 924(e). We reject the double jeopardy claim but

agree that Rodríguez should not have been sentenced as an armed

career criminal.

BACKGROUND

In November 2004, Rodríguez participated in a carjacking

in Puerto Rico while possessing a firearm. That conduct resulted

in successive prosecutions in the Puerto Rico Commonwealth courts

and the United States District Court for the District of Puerto

Rico. Rodríguez was first prosecuted in a Commonwealth court for

robbery of a motor vehicle in violation Article 173B of the Puerto

Rico Penal Code, P.R. Laws Ann. tit. 33 § 4279b (repealed 2004),

and for carrying a weapon without a license in violation of Article

5.04 of the Puerto Rico Weapons Law, P.R. Laws Ann. tit. 25, § 458c

(repealed 2013). Rodríguez pleaded guilty and was sentenced to

twelve years in prison.

Following the Commonwealth conviction, a federal grand

jury indicted Rodríguez on three counts arising from the same

- 2 - carjacking: aiding and abetting a carjacking, 18 U.S.C. §§ 2 and

2119; aiding and abetting the use of a firearm during and in

relation to a crime of violence, 18 U.S.C. §§ 2 and 924(c); and

unlawful possession of a firearm by a felon

("felon-in-possession"), 18 U.S.C. §§ 922(g)(1) and 924(a)(2).1

In addition, because he had at least three prior convictions for

robbery of a motor vehicle in violation of Article 173B, Rodríguez

was charged as an armed career criminal pursuant to the Armed

Career Criminal Act, 18 U.S.C. § 924(e) [hereinafter ACCA or the

Act].2

Rodríguez pleaded guilty to the felon-in-possession

count and the government dismissed the other charges. He was

sentenced in November 2006. Due in part to the ACCA's heightened

statutory penalties, Rodríguez received 216 months of

imprisonment. Rodríguez filed a notice of appeal but voluntarily

dismissed the appeal in October 2008. Rodríguez did not

1 When Rodríguez was indicted, the penalty provision for § 922(g) was § 924(a)(2). "The Bipartisan Safer Communities Act, Pub. L. No. 117-159, § 12004, 136 Stat. 1313, 1329 (2022), has since moved the penalty provision . . . to [§] 924(a)(8), which provides for a longer maximum period of imprisonment." United States v. Minor, 63 F.4th 112, 118 n.4 (1st Cir. 2023). All subsequent references to § 924(a)(2) are to the provision as it existed at the time of the indictment. 2 The presentence investigation report identified the ACCA predicates as convictions for armed robbery under Article 173 of the Puerto Rico Penal Code. The parties agree that the convictions, in fact, were for robbery of a motor vehicle in violation of Article 173B.

- 3 - collaterally attack his conviction within a year of it becoming

final.

Two significant legal developments followed. In June

2015, roughly a decade after Rodríguez's felon-in-possession

conviction, the United States Supreme Court held that the residual

clause of the ACCA was unconstitutionally vague. Johnson v.

United States (Johnson II), 576 U.S. 591, 597 (2015).

Then, a year later, in June 2016, the Supreme Court held

that the Commonwealth of Puerto Rico and the United States are one

sovereign for double jeopardy purposes, thereby barring successive

prosecutions for the same offense in Commonwealth and federal

courts. Puerto Rico v. Sánchez Valle, 579 U.S. 59, 78 (2016).

About three months after the Supreme Court decided

Sánchez Valle, Rodríguez filed a pro se motion for habeas relief

under 28 U.S.C. § 2255 seeking to vacate his felon-in-possession

conviction on double jeopardy grounds. After the appointment of

counsel, Rodríguez amended his motion to challenge his ACCA

enhancement, arguing that following Johnson II, his three prior

Article 173B convictions no longer qualified as predicate offenses

under the ACCA.

The district court rejected both claims. It held that

double jeopardy did not bar Rodríguez's federal

felon-in-possession prosecution because Rodríguez "failed to meet

the stone set privity requirement necessary for his double jeopardy

- 4 - claim to thrive." It also held that even after Johnson II, an

Article 173B conviction constitutes an ACCA predicate because the

offense has as an element the use, attempted use, or threatened

use of physical force as defined by the ACCA. The district court

concluded that was so because Article 173B requires a defendant to

commit motor vehicle robbery using "an object capable of causing

grave bodily injury." The district court denied certificates of

appealability on both claims. Rodríguez appealed, and this Court

granted him the required certificates.

DOUBLE JEOPARDY

On appeal, the government does not argue privity but

instead proffers two alternative bases to affirm the district

court's double jeopardy ruling. See Miller v. United States, 77

F.4th 1, 6 (1st Cir.

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