Ruelas v. United States

CourtDistrict Court, D. Arizona
DecidedApril 20, 2020
Docket2:20-cv-00372
StatusUnknown

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

Bluebook
Ruelas v. United States, (D. Ariz. 2020).

Opinion

1 WO MDR 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 9 United States of America, No. CV 20-00372-PHX-JAT (JZB) 10 Plaintiff, CR 17-00317-001-PHX-JAT 11 v. ORDER 12 Silvester Ruelas, 13 Defendant/Movant.

14 15 On February 18, 2020, Movant Silvester Ruelas, who is confined in the Federal 16 Correctional Institution-La Tuna in Anthony, New Mexico, filed a pro se Petition Under 17 28 U.S.C. Section 2255 to Vacate or Set Aside the Conviction or Correct Sentence. In a 18 February 24, 2020 Order, the Court denied the Petition because Movant failed to file on a 19 court-approved form. The Court gave Movant 30 days to file an amended motion that 20 cured the deficiencies identified in the Order. 21 On April 6, 2020, Movant filed his Amended § 2255 Motion (Doc. 5). The Court 22 will call for an answer to Grounds One, Two, and Four of the Amended § 2255 Motion and 23 will dismiss Ground Three. 24 I. Procedural History 25 Pursuant to a plea agreement, Movant pleaded guilty to Conspiracy to Possess with 26 Intent to Distribute Cocaine and Money Laundering Conspiracy. On February 20, 2019, 27 the Court sentenced Movant to a 240-month term of imprisonment followed by 60 months 28 on supervised release. 1 II. Amended § 2255 Motion 2 A. Issues Raised in the Amended § 2255 Motion 3 In the Amended § 2255 Motion, Movant raises four grounds for relief. In Ground 4 One, Movant contends the government “impermissibly denied [Movant] safety valve 5 relief” by “walking away unceremoniously from a meeting with [Movant] on the subject 6 of granting safety value, for no legally cognizable reason.” 7 In Ground Two, Movant claims his counsel was “grossly ineffective for not 8 subjecting the [gov[ernmen]t’s case to strict adversarial testing.” Movant contends his 9 counsel was ineffective: for failing to subpoena Movant’s co-defendant’s plea agreement 10 and presentence report to look for factual inaccuracies; because the government made 11 stipulations regarding Movant’s co-defendant that “amended the charges against 12 [Movant]”; by failing to call and interview Movant’s co-defendant and potential witnesses 13 in preparation for trial; and at sentencing. 14 In Ground Three, Movant alleges the Court “may have abused its discretion by 15 reason of a procedural[] and substantive unreasonableness.” Movant claims the Court 16 failed to hold an evidentiary hearing regarding the safety valve issue, adopted wholesale 17 the government’s enhancement recommendations, and imposed a disproportionate 18 sentence “with respect to [Movant’s] role in the conspiracy vis a vis his co-defendant,” 19 who “not only orchestrated the conspiracy[,] but was the undisputed leader of the 20 conspiracy.” 21 In Ground Four, Movant asserts there was prosecutorial misconduct in stipulations 22 the government made in Movant’s co-defendant’s proceeding, which constructively 23 amended Movant’s indictment. 24 B. Waived and Unwaived Claims 25 The Ninth Circuit Court of Appeals has found that there are “strict standards for 26 waiver of constitutional rights.” United States v. Gonzalez-Flores, 418 F.3d 1093, 1102 27 (9th Cir. 2005). It is impermissible to presume waiver from a silent record, and the Court 28 must indulge every reasonable presumption against waiver of fundamental constitutional 1 rights. United States v. Hamilton, 391 F.3d 1066, 1071 (9th Cir. 2004). In this action, 2 Movant’s waiver was clear, express, and unequivocal. 3 Plea agreements are contractual in nature, and their plain language will generally be 4 enforced if the agreement is clear and unambiguous on its face. United States v. Jeronimo, 5 398 F.3d 1149, 1153 (9th Cir. 2005). A defendant may waive the statutory right to bring 6 a § 2255 action challenging the length of the sentence. United States v. Pruitt, 32 F.3d 7 431, 433 (9th Cir. 1994); United States v. Abarca, 985 F.2d 1012, 1014 (9th Cir. 1992). 8 The only claims that cannot be waived are claims that the waiver itself was involuntary or 9 that ineffective assistance of counsel rendered the waiver involuntary. See Washington v. 10 Lampert, 422 F.3d 864, 871 (9th Cir. 2005) (holding that a plea agreement that waives the 11 right to file a federal habeas petition pursuant to § 2254 is unenforceable with respect to an 12 ineffective assistance of counsel claim that challenges the voluntariness of the waiver); 13 Pruitt, 32 F.3d at 433 (expressing doubt that a plea agreement could waive a claim that 14 counsel erroneously induced a defendant to plead guilty or accept a particular plea bargain); 15 Abarca, 985 F.2d at 1014 (expressly declining to hold that a waiver forecloses a claim of 16 ineffective assistance or involuntariness of the waiver); see also Jeronimo, 398 F.3d at 17 1156 n.4 (declining to decide whether waiver of all statutory rights included claims 18 implicating the voluntariness of the waiver). 19 As part of Movant’s plea agreement, Movant made the following waiver: 20 The defendant waives (1) any and all motions, defenses, probable 21 cause determinations, and objections that the defendant could assert to the indictment or information; and (2) any right to file an appeal, 22 any collateral attack, and any other writ or motion that challenges the 23 conviction, . . . the entry of judgment against the defendant, or any aspect of the defendant’s sentence, including the manner in which the 24 sentence is determined, including but not limited to . . . motions under 25 28 U.S.C. §§ 2241 and 2255 (habeas petitions) . . . . This waiver shall result in the dismissal of any appeal, collateral attack, or other motion 26 the defendant might file challenging the conviction, . . . or sentence in 27 this case. This waiver shall not be construed to bar an otherwise- preserved claim of ineffective assistance of counsel or of 28 “prosecutorial misconduct” (as that term is defined by Section II.B of 1 Ariz. Ethics Op. 15-01 (2015)). 2 3 (Doc. 191). Movant indicated in the plea agreement that he had discussed the terms with 4 his attorney, agreed to the terms and conditions, and entered into the plea voluntarily. (Id.) 5 Movant’s assertions in the § 2255 Motion do not pertain to the voluntariness of the 6 waiver. Movant expressly waived issues regarding the imposition of sentence and 7 expressly waived the right to bring a § 2255 motion, except as to claims of ineffective 8 assistance of counsel and prosecutorial misconduct. The Court accepted the plea as 9 voluntarily made. 10 The issue in Ground Three pertains to the imposition of the sentence. The Court 11 finds this issue waived and will dismiss it. 12 The issues raised in Grounds Two (ineffective assistance) and Four (prosecutorial 13 misconduct) were not waived in the plea agreement. Although not entirely clear, the issue 14 raised in Ground One (impermissibly denying safety valve relief) is arguably a 15 prosecutorial misconduct claim and, therefore, was not waived in the plea agreement. 16 Thus, the Court will require a response to Grounds One, Two, and Four. 17 III.

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