Ruiz v. Spearman

CourtDistrict Court, N.D. California
DecidedApril 1, 2024
Docket3:18-cv-07681
StatusUnknown

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

Bluebook
Ruiz v. Spearman, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 IGNACIO RUIZ, Case No. 18-cv-07681-EMC (EMC) 8 Plaintiffs, ORDER CLARIFYING THIS COURT'S 9 v. APRIL 10, 2023 ORDER 10 M.ELIOT SPEARMAN, Docket No. 63 11 Defendants. 12 I. INTRODUCTION 13 This case arises from the conviction of Ignacio Ruiz in the Contra Costa Superior Court 14 and remedy granted to Mr. Ruiz per his petition for a writ of habeas corpus by this Court 15 thereafter. Mr. Ruiz was offered a plea deal in 2012 that this Court found he rejected due to 16 ineffective assistance of counsel in violation of the Sixth Amendment. After rejecting the deal, 17 Mr. Ruiz lost at trial. He was convicted of first-degree murder, among other charges, and received 18 a sentence less favorable than that in the deal; he was sentenced to life imprisonment without 19 parole. He was also convicted of counts to which he would not have pled guilty under the plea 20 deal. To remedy the harm from the ineffective assistance, this Court ordered the government to 21 re-offer the original plea deal, which required Mr. Ruiz to plead guilty to two counts of second- 22 degree murder in exchange for a 15-years-to-life sentence, with dismissal of all other counts and 23 enhancements sought. After the order granting the habeas petition, the government offered a plea 24 to Mr. Ruiz that added a waiver of Mr. Ruiz’s right to pursue resentencing under California Penal 25 Code section 1172.6—a law allowing resentencing for those convicted of murder pursuant to a 26 theory of imputed malice or intent, such as felony murder. That waiver was not in the original 27 plea as section 1172.6 was not in existence in 2012 as it did not become law until 2019. The 1 waiver. Mr. Ruiz now asks this Court for clarification of the remedy that it ordered in its April 10, 2 2023, decision when it ordered the government to reoffer the “original plea” from 2012. In 3 particular, is it appropriate to include the waiver of rights under section 1172.6 in the new plea 4 deal? 5 The “original plea,” this Court ordered the government to re-offer to Mr. Ruiz did not 6 include a waiver of the right to pursue relief under Cal. Pen. Code § 1172.6. The purpose of the 7 relief ordered by this Court was to put Mr. Ruiz in the position he would have been in but for the 8 ineffective assistance of counsel – to replicate the plea offer made in 2012. The proposed waiver 9 is a new element and not appropriate for inclusion as a condition of the plea. In the but-for world, 10 Mr. Ruiz would have pled guilty to fewer counts, received a shorter sentence, and would still have 11 had the opportunity to pursue resentencing under section 1172.6, a statue enacted years later. 12 Thus, the Court clarifies its intent that the District Attorney re-offer to Mr. Ruiz the plea 13 deal wherein Mr. Ruiz is required to plead guilty to two counts of second-degree murder, carrying 14 two concurrent indeterminate sentences of 15 years to life, and wherein the government is to drop 15 all other charges and enhancements, i.e., the plea originally offered. The Court did not intend that 16 the plea offer include a section 1172.6 waiver since that was not part of the original deal. 17 II. FACTUAL AND PROCEDURAL BACKGROUND 18 A. Background of the case 19 Petitioner Ignacio Ruiz was charged with conspiracy to commit murder (Cal. Penal Code 20 §§ 182 (a)(1), 187), two counts of first-degree murder (Cal. Penal Code § 187) with multiple 21 special circumstance allegations (Cal. Penal Code §§ 190.2(a)(3), (a)(22)), and active participation 22 in a criminal street gang (Cal. Penal Code § 186.22(a)). See Docket No. 14 (“Habeas Order”) at 1. 23 The charges included firearm enhancement allegations (Cal. Penal Code § 12022.53) and alleged 24 that the conspiracy and murder counts were committed for the benefit of a criminal street gang 25 (Cal. Penal Code § 186.22). Id. at 1. The first-degree murder charges carried a sentence of life 26 imprisonment without the possibility of parole. 27 In 2012, the District Attorney offered a pretrial plea of two counts of second-degree 1 enhancements. Id. at 3 (citing Docket No. 7 (“Ans.”), Exh. 11 at 1 (“On February 18, 2012, the 2 Contra Costa County District Attorney offered to drop all other charges and enhancements if 3 Petitioner pleaded guilty to two counts of second-degree murder, carrying two concurrent 4 indeterminate sentences of 15 years to life.”)). Based on advice from Mr. Ruiz’s counsel, Daniel 5 Cook and Kellin Cooper, that: (1) no lifers ever received parole (advice consistent with Mr. 6 Cooper’s earlier statement to Mr. Ruiz that “if he took a plea that did not include a guaranteed 7 release date he would never be paroled,” Docket No. 58-1 Exh. 1 (Declaration of Kellin Cooper 8 (“Cooper Decl.”)) ¶ 5), and (2) he could rely on an accessory-after-the-fact instruction at trial 9 (which would have permitted the jury to convince on a lesser offense), Mr. Ruiz rejected the deal. 10 See Docket No. 15 (“Mot. to Alter Judgment”) at 1. Mr. Ruiz proceeded to trial. 11 At trial in the Contra Costa County Superior Court, the trial judge rejected Mr. Cook’s 12 request for the lesser offense jury instruction. Mr. Ruiz was convicted of two counts of first-degree 13 murder, conspiracy to commit murder, and active participation in a criminal street gang, with 14 multiple murder and gang special circumstances and gang and firearm enhancements. See Cal. 15 Penal Code §§ 182(a)(1), 186.22(a) & (b)(1)), 187, 190.2(a)(3), (a)(22), 12022.53(b)–(d)). Mr. 16 Ruiz was then sentenced to 50 years to life and two consecutive terms of life without parole. The 17 California Court of Appeal affirmed the judgment on direct appeal. Habeas Order at 4. The 18 California Supreme Court denied Mr. Ruiz’s petition for review in 2016. Docket No. 7-5. Mr. 19 Ruiz filed a habeas petition directly before the California Supreme Court, asserting ineffective 20 assistance of counsel via his counsel’s ill-advice on the law regarding parole and the lesser-related 21 offense instructions. That petition was denied in 2018, without any comment. Docket No. 7-6. 22 On August 13, 2020, this Court granted Petitioner Ignacio Ruiz’s petition for a writ of 23 habeas corpus pursuant to 28 U.S.C. § 2254 challenging his conviction from Contra Costa County 24 Superior Court. Habeas Order. Respondent M. Eliot Spearman (“the government”) filed a motion 25 to alter or amend the judgment and request for evidentiary hearing pursuant to Federal Rule of 26 Civil Procedure 59(e). Docket No. 15 (“Mot. to Amend”). The Court granted the government’s 27 request for an evidentiary hearing, recognizing that the Court should consider evidence regarding 1 Respondent’s Request for Evidentiary Hearing); Docket No. 62 (Order Denying Defendant’s 2 Motion to Alter or Amend Judgment).1 On January 6 and 9, 2023, this Court held an evidentiary 3 hearing and received testimony from Mr. Cook and Mr. Ruiz regarding: (1) the likelihood of 4 parole had Mr. Ruiz pled to two second degree murder charges with indeterminate sentences of 5 fifteen years to life, and (2) the availability of a defense at trial based on a lesser included offense 6 of accessory after the fact, as well as (3) whether Mr. Ruiz was prejudiced by Mr. Cook’s advice. 7 Thereafter, in consideration of the evidence presented at that hearing, the Court found in favor of 8 Mr. Ruiz, including finding he was prejudiced by the erroneous advice at issue, and denied 9 Government’s Motion to Alter or Amend the Judgment, pursuant to Federal Rule 59(e) on April 10 10, 2023. See Docket No. 62 (“Final Habeas Order”).

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Ruiz v. Spearman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ruiz-v-spearman-cand-2024.