Sanchez v. United States

CourtDistrict Court, W.D. Oklahoma
DecidedSeptember 5, 2024
Docket5:22-cv-00085
StatusUnknown

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

Bluebook
Sanchez v. United States, (W.D. Okla. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) Case No. CR-17-122-6-SLP ) CIV-22-85-SLP JOSE MANUAL MARQUEZ SANCHEZ, ) ) Defendant. )

O R D E R

Before the Court is Defendant’s pro se Motion Under 28 U.S.C. § 2255 to Vacate, Set Aside, or Correct Sentence by a Person in Federal Custody [Doc. No. 822], to which the Government has responded [Doc. No. 830] and Defendant has replied [Doc. No. 834]. Also before the Court are Defendant’s Motions for Status Update [Doc. Nos. 867 and 872]. These matters are at issue. Upon review and for the reasons that follow, the § 2255 Motion is DENIED and the Motions for Status Update are DENIED as MOOT. I. Factual and Procedural History On May 29, 2018, a jury found Defendant guilty of multiple drug-related charges, including conspiracy to possess with intent to distribute and distribution of methamphetamine or cocaine hydrochloride. See Verdict [Doc. No. 555] (finding Defendant guilty of Counts 1, 30, 31, 38, 41, 42, 44, 57, 59 and 90 of the Amended Superseding Indictment [Doc. No. 507]). Defendant was sentenced to a total term of 132 months’ imprisonment.1

1 Defendant’s sentence has been reduced to 121 months pursuant to his Motion for Sentence Defendant filed a direct appeal of his conviction and argued that a fatal variance existed between the conspiracy charged and the evidence presented at trial. He also challenged the quantity of drugs this Court attributed to him at sentencing. The Tenth

Circuit affirmed his conviction. See United States v. Sanchez, 979 F.3d 1256 (10th Cir. 2020). Defendant was represented by appointed counsel, Jeffrey D. Trevillion, Jr., in proceedings before the district court. He was represented by appointed counsel, Ty Gee, on direct appeal of his conviction.

II. Defendant’s § 2255 Claims Defendant brings four claims of ineffective assistance of trial and appellate counsel. First, he argues trial counsel did not object to the jury instructions as a constructive amendment of the drug conspiracy charge (Count I of the Indictment). Second, Defendant argues his trial counsel should have moved to dismiss the Indictment based on a violation

of the Speedy Trial Act and his Sixth Amendment right to a speedy trial. Third, Defendant claims that his trial counsel did not properly investigate and challenge the drug conspiracy charge. Fourth, Defendant contends his trial counsel should have moved to sever his case from the other ten co-defendants. Defendant claims appellate counsel was ineffective for failing to raise these claims on direct appeal.

III. Discussion Defendant’s ineffective assistance of counsel claims are governed by the well-

Reduction based on the retroactive application of Amendment 821 to the U.S. Sentencing Guidelines. See Order [Doc. No. 864]. established framework set forth in Strickland v. Washington, 466 U.S. 668, 687-88 (1984). To establish ineffective assistance of counsel, a movant must show (1) that counsel’s representation was deficient because it “fell below an objective standard of reasonableness”

and (2) that counsel’s “deficient performance prejudiced the defense.” Id. To establish ineffective assistance of appellate counsel, the court examines the merits of the omitted issue. If the omitted issue is meritless, its omission does not constitute deficient performance. Frederick v. Quick, 79 F.4th 1090, 1105 (10th Cir. 2023); see also Harmon v. Sharp, 936 F.3d 1044, 1063 (10th Cir. 2019) (“[A]n ineffective assistance of

appellate counsel claim lacks merit if the [defendant] argues that appellate counsel should have asserted meritless ineffective assistance of trial counsel claims.”). As to the prejudice prong, the defendant must show a reasonable probability that but for counsel’s unreasonable failure to raise a particular non-frivolous issue, he would have prevailed on his appeal. Id.

“The court may address the two Strickland prongs in either order and need not address both if the defendant has failed to satisfy one.” Id. (citing Strickland, 466 U.S. at 697). A. Alleged Constructive Amendment of Count 1 Defendant claims a constructive amendment of Count 1 of the Superseding

Indictment [Doc. No. 244] occurred because Count 1 alleged a conspiracy to distribute methamphetamine and cocaine hydrochloride but the jury instructions permitted the jury to convict for a conspiracy to distribute methamphetamine or cocaine hydrochloride. Defendant specifically references Jury Instruction No. 25, see Doc. No. 552 at 38-39, and contends his counsel should have objected to the instruction. This claim is rejected. “A constructive amendment of an indictment occurs when the terms of the

indictment are in effect altered by the presentation of evidence and jury instructions which so modify essential elements of the offense charged that there is a substantial likelihood that the defendant may have been convicted of an offense other than that charged in the indictment.” United States v. Gauvin, 173 F.3d 798, 805 (10th Cir.1999) (quoting United States v. Hornung, 848 F.2d 1040, 1046 (10th Cir.1988)). Here, no such constructive

amendment occurred. “It is hornbook law that a crime denounced in the statute disjunctively may be alleged in an indictment in the conjunctive, and thereafter proven in the disjunctive.” United States v. DeChristopher, 695 F.3d 1082, 1095 (10th Cir. 2012). As the Government argues, this principle has been applied to drug conspiracy cases. See Resp. at 4 (citing,

inter alia, United States v. Atencio, 435 F.3d 1222, 1229 n. 2 (10th Cir. 2006) (finding legal challenge had “no merit” where it was based on fact that “Count 1 of the indictment charged that ‘the violations involved at least 30,000 kilograms of marijuana and 150 kilograms of cocaine,’ . . . while the jury instructions allowed for a conviction based on an enterprise that ‘involved at least 30,000 kilograms of marijuana . . . or 150 kilograms of cocaine’”).

Because this claim lacks merit, it necessarily follows that neither trial nor appellate counsel were ineffective for failing to raise the claim. Accordingly, Ground One is denied. B. Speedy Trial Rights Defendant next argues a motion to dismiss should have been filed on grounds his right to a speedy trial was violated. Defendant correctly asserts that he was arraigned on

July 6, 2017 and that his speedy trial clock commenced at that time. He argues that delays between July 6, 2017 and November 27, 2017 were unreasonable and “the Court issued no excludable time on the record from the Speedy Trial clock.” Mot. at 5. Defendant further argues that on November 28, 2017, he was arraigned on a Superseding Indictment and that from that date, until May 29, 2018, “no excludable time,

good cause or reason was set on the record” resulting in a violation of his speedy trial rights. According to Defendant, his case was “not complex or unusual” and the delays “were unreasonable because plea reduced the chance of a Complex Federal Criminal Matter in violation of his Sixth Amendment Rights to a speedy trial.” Mot. at 6. He claims resulting prejudice in wholly conclusory fashion stating that his “Jury Trial resulted in an

unreliable or fundamentally unfair outcome of the proceedings.” Id. 1.

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