Rodriguez v. United States

District Court, S.D. New York·Decided August 28, 2024·No. 1:20-cv-09097·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JOVANNY RODRIGUEZ, 20 Civ. 9097 (JFK) Movant, -v.- 11 Cr. 755-3 (KPF) UNITED STATES OF AMERICA, ORDER Respondent. KATHERINE POLK FAILLA, District Judge:1 This Order resolves several outstanding motions that were filed by Movant-Defendant Jovanny Rodriguez after the transfer of his criminal case from Judge John F. Keenan to this Court. The underlying criminal conduct for which Mr. Rodriguez was prosecuted — his participation in a violent armed robbery crew that targeted drug dealers and legitimate business owners over a period of years — as well as the complex procedural history of the prosecution, are detailed in numerous prior opinions, familiarity with which is assumed. See, e.g., United States v. Rodriguez, No. 11 Cr. 755 (JFK), 2014 WL 715614

(S.D.N.Y. Feb. 24, 2014) (opinion and order denying motions for judgment of acquittal and for new trial); United States v. Rodriguez, 761 F. App’x 53 (2d Cir.) (summary order) (opinion affirming conviction), cert. denied, 140 S. Ct. 473 (2019); Rodriguez v. Derienzo, No. 20 Civ. 87 (CM), 2020 WL 615052 (S.D.N.Y. Feb. 7, 2020) (opinion and order dismissing pro se complaint seeking

1 Unless otherwise indicated, references to docket entries are to the docket in Mr. Rodriguez’s criminal case, No. 11 Cr. 755-3 (KPF), and references to page numbers in Mr. Rodriguez’s submissions are to the numbers supplied by this Court’s electronic case filing (“ECF”) system. prosecution of law enforcement officer who testified before grand jury); United States v. Rodriguez, No. 11 Cr. 755 (JFK), 2021 WL 37689 (S.D.N.Y. Jan. 5, 2021) (opinion and order denying motion for compassionate release pursuant

to 18 U.S.C. § 3582(c)(1)(A)(i) and, in the alternative, for bail) (“Rodriguez 3582 Opinion”), motion for reconsideration denied, 2022 WL 2801009 (S.D.N.Y. July 18, 2022) (“Rodriguez 3582 Reconsideration Opinion”); United States v. Rodriguez, No. 11 Cr. 755 (JFK), 2022 WL 2805536 (S.D.N.Y. July 18, 2022) (opinion and order denying motion to vacate, set aside, or correct sentence pursuant to 28 U.S.C. § 2255 and denying certificate of appealability) (“Rodriguez 2255 Opinion”); United States v. Rodriguez, No. 22-1684 (2d Cir. Dec. 15, 2022) (denying motion for certificate of appealability).

Because the instant motions are largely duplicative of prior motions that Mr. Rodriguez has made, the Court has not requested supplemental responses from the Government. For the reasons set forth in the remainder of this Order, the Court denies Mr. Rodriguez’s most recent motions. A. The Court Denies Mr. Rodriguez’s Motion to Vacate Its Prior Order Denying His Motion Pursuant to 28 U.S.C. § 2255 1. Relevant Facts In October 2013, Mr. Rodriguez was convicted after a jury trial of robbery, kidnapping, narcotics, and firearms offenses, for which he was ultimately sentenced to an aggregate term of life plus 32 years’ imprisonment. (Dkt. #265 (judgment)). In October 2020, Mr. Rodriguez moved to vacate, set aside, or correct his sentence pursuant to 28 U.S.C. § 2255. (Dkt. #450).2 Broadly speaking, Mr. Rodriguez claimed ineffective assistance on the part of his trial counsel and misconduct on the part of one of the Government’s

witnesses. As is customary in this District, Judge Keenan, to whom this case was then assigned, ordered that Mr. Rodriguez’s trial counsel submit an affidavit responding to Mr. Rodriguez’s claims of ineffectiveness. (Dkt. #517 (order), 527 (affidavit)). While accepting counsel’s affidavit, Judge Keenan elected not to hold a plenary hearing on the Section 2255 motion, concluding that “the motion and the files and records of the case conclusively show[ed] that” Mr. Rodriguez was not entitled to any relief. Rodriguez 2255 Opinion, 2022 WL 2805536, at *4 (quoting 28 U.S.C. § 2255(b)).

Ultimately, Judge Keenan found that Mr. Rodriguez had failed to demonstrate ineffectiveness on the part of his trial counsel, and that his claims of prosecutorial misconduct were both procedurally defaulted and deficient on the merits. Rodriguez 2255 Opinion, 2022 WL 2805536, at *4-9. At the conclusion of his opinion, Judge Keenan declined to issue a certificate of appealability, finding that “[Mr.] Rodriguez has not made a substantial showing of a denial of a constitutional right.” Id. at *9. Mr. Rodriguez moved for a certificate of appealability from the United States Court of Appeals for the

Second Circuit, which denied his motion and dismissed his appeal. (Dkt. #560 (mandate)).

2 Motions filed pursuant to 28 U.S.C. § 2255 are sometimes referred to as federal habeas petitions. This Court uses both terms interchangeably in this Order. Mr. Rodriguez now moves to vacate Judge Keenan’s order denying his Section 2255 motion pursuant to Rule 60(b) of the Federal Rules of Civil Procedure, claiming that (i) Judge Keenan’s decision was predicated on a

mistake of law and (ii) the Supreme Court has recognized that a motion under Rule 60(b)(1) is the proper vehicle for challenging an order predicated on a mistake of law. (Dkt. #565 (citing Kemp v. United States, 596 U.S. 528 (2022))). Acknowledging that Rule 60(b) may only be invoked in the case of a challenge to the integrity of the federal habeas proceeding itself, Mr. Rodriguez proffers two such challenges, namely, challenges to: (i) Judge Keenan’s decision not to hold a plenary hearing on the Section 2255 motion and (ii) Judge Keenan’s refusal to issue a certificate of appealability. (Id. at 10-20). As set forth in the

remainder of this section, Mr. Rodriguez has identified no basis for Rule 60(b) relief. 2. Applicable Law Federal Rule of Civil Procedure 60(b) states that [o]n motion and just terms, the court may relieve a party or its legal representative from a final judgment, order, or proceeding for the following reasons: (1) mistake, inadvertence, surprise, or excusable neglect; (2) newly discovered evidence that, with reasonable diligence, could not have been discovered in time to move for a new trial under Rule 59(b); (3) fraud (whether previously called intrinsic or extrinsic), misrepresentation, or misconduct by an opposing party; (4) the judgment is void; (5) the judgment has been satisfied, released or discharged; it is based on an earlier judgment that has been reversed or vacated; or applying it prospectively is no longer equitable; or (6) any other reason that justifies relief. Fed. R. Civ. P. 60(b). A motion made under Rule 60(b)(1), (2), or (3) “must be made within a reasonable time,” but in any event “no more than a year after the entry of the judgment or order or the date of the proceeding.” Fed. R. Civ.

P. 60(c)(1). Motions brought pursuant to Rule 60(b)(4), (5), or (6), on the other hand, need only be “made within a reasonable time.” Id. Mr. Rodriguez has already filed a Section 2255 motion that was denied by Judge Keenan. As potentially relevant here, 28 U.S.C.

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