Sanchez v. United States

CourtDistrict Court, N.D. Texas
DecidedJune 11, 2024
Docket3:22-cv-01945
StatusUnknown

This text of Sanchez v. United States (Sanchez v. United States) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas 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, (N.D. Tex. 2024).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION JESUS GUERRA-SANCHEZ, § ID # 55800-177, § Movant, § § No. 3:22-CV-1945-B-BK v. § No. 3:17-CR-341-B(5) § UNITED STATES OF AMERICA, § Respondent. § MEMORANDUM OPINION AND ORDER Based on the relevant filings and applicable law, the pro se motion to vacate, set aside, or correct sentence under 28 U.S.C. § 2255, received on September 1, 2022 (doc. 1), is DENIED and this action is DISMISSED WITH PREJUDICE. I. BACKGROUND Movant Jesus Guerra-Sanchez1 (Movant) challenges his federal conviction and sentence in Cause No. 3:17-CR-341-B-5. The respondent is the United States of America (Government). A. Conviction and Sentencing After first being charged by complaint and indictment with others, Movant was charged by superseding indictment with one count of conspiracy to distribute a controlled substance. (See docs. 1, 43, 84.)2 He pled guilty to the conspiracy count under a plea agreement. (See docs. 248, 338.) The plea agreement reflected that Movant understood the nature and elements of the crime to which he was pleading guilty, and that the factual resume he signed was true and would be 1 Movant states that his name has been incorrectly written as Jesus Guerra-Sanchez, rather than as his correct name, Jesus Sanchez-Guerra. (See No. 3:22-CV-1945-B-BK, doc. 11 at 5.) As Movant’s entire criminal proceedings and the Bureau of Prisons identify him as Jesus Guerra-Sanchez, this action does the same in the interest of consistency and to avoid confusion. 2 Unless otherwise indicated, all document numbers refer to the docket number assigned in the underlying criminal action, 3:17-CR-341-B(5). submitted as evidence. (See doc. 248 at 1-2.)3 It set out the minimum and maximum penalties for the conspiracy count; it stated that Movant had reviewed the advisory federal sentencing guidelines with counsel, and he understood his sentence would be imposed by the court after consideration of

the guidelines and no one could predict with certainty the outcome of the court’s consideration of the guidelines. (See id. at 2-3.) He agreed the guilty plea was freely and voluntarily made and was not the result of force or threats, or of promises apart from those set forth in the plea agreement; there were no guarantees or promises from anyone about what sentence the court would impose. (See id. at 6.) On July 10, 2018, Movant appeared for his rearraignment. (See doc. 973.) He testified under oath through an interpreter that: he understood that a guilty plea must not be induced or prompted

in any way by promises, threats, force, or coercion, and that it must be purely voluntary and entered only because he was guilty and for no other reason; the plea documents were translated into Spanish and read to him in their entirety, and he fully understood and discussed them in detail with counsel before he signed them; he understood the essential elements of the conspiracy count and had committed each of them; he understood by pleading guilty, he was exposing himself to a sentence of imprisonment of not less than 10 years and not to exceed life; he was fully satisfied with his

counsel’s representation; he understood that he was waiving his right to appeal and otherwise challenge his sentence and conviction except in very limited circumstances; and no one made any promise or assurance or asserted force of any kind to get him to plead guilty. (See id. at 7-8, 13-21.) The United States Probation Office (USPO) prepared a pre-sentence investigation report

3 Citations to the record refer to the CM/ECF system page number at the top of each page rather than the page numbers at the bottom of each filing. 2 (PSR) for purposes of sentencing, which reflected that Movant’s base offense level was 38 based on the drug quantities for which he was held accountable. (See doc. 420-1 at ¶¶ 49, 57.) Two levels were added because the offense involved methamphetamine imported from Mexico, three levels were

added based on Movant’s role as a manager or supervisor in the criminal activity, and three levels were deducted for acceptance of responsibility, resulting in a total offense level of 40. (See id. at ¶¶ 58, 60, 64-66.) Based on a total offense level of 40 and criminal history category of I, his guideline imprisonment range was 292 to 365 months. (See id. at ¶ 103.) Movant filed objections to the PSR, the USPO supported the PSR as written in an addendum, and Movant filed objections to the PSR addendum. (See docs. 709, 715-1, 733.) Movant’s first sentencing hearing was continued for consideration of the possibility of a duress

defense. (See doc. 939.) At the second sentencing hearing, the court overruled Movant’s objections to the PSR and addendum, found that there was not enough proof to Movant’s allegations of duress, and granted a three-level downward departure on the Government’s motion, resulting in a guideline imprisonment range of 210 to 262 months. (See doc. 940.) Movant was sentenced to a term of imprisonment of 230 months, to be followed by five years of supervised release. (See doc. 916.) The Fifth Circuit dismissed his direct appeal. (See docs. 1006-07.) Movant did not file a petition for a writ

of certiorari with the Supreme Court. B. Substantive Claims Movant’s § 2255 motion alleges that: his conviction was based on insufficient evidence, or, alternatively, his guilty plea was not knowingly, voluntarily, and intelligently made; trial counsel rendered ineffective assistance; and appellate counsel rendered ineffective assistance. (See No. 3:22- CV-1945-B-BK, doc. 1 at 7-8.) The Government filed a response on December 27, 2022. (See id., 3 doc. 18.) Movant did not file a reply. II. SCOPE OF RELIEF UNDER § 2255 After conviction and exhaustion or waiver of the right to direct appeal, the court presumes

that a defendant has been fairly and finally convicted. United States v. Cervantes, 132 F.3d 1106, 1109 (5th Cir. 1998) (citing United States v. Shaid, 937 F.2d 228, 231-32 (5th Cir. 1991) (en banc)). Post- conviction “[r]elief under 28 U.S.C. § 2255 is reserved for transgressions of constitutional rights and for a narrow range of injuries that could not have been raised on direct appeal and would, if condoned, result in a complete miscarriage of justice.” United States v. Gaudet, 81 F.3d 585, 589 (5th Cir. 1996) (citation and internal quotation marks omitted); see also United States v. Willis, 273 F.3d 592, 595 (5th Cir. 2001) (“A defendant can challenge a final conviction, but only on issues of

constitutional or jurisdictional magnitude.”). III. SUFFICIENCY OF EVIDENCE Movant contends that his “conviction is infirm as it is based on insufficient evidence to satisfy the essential elements of the charged offense[.]” (No. 3:22-CV-1945-B-BK, doc. 1 at 7.) His claim appears to be premised on the theory that he lacked the requisite mens rea for the offense of conviction because he committed it under duress or coercion. (See e.g., id., doc. 11 at 11-13.)

Even if the court assumes for purposes of this motion only that this claim is not procedurally defaulted because it was not raised on direct appeal or waived by Movant’s appeal waiver, it fails on the merits. The record shows that Movant signed a factual resume admitting he committed each of the essential elements of the offense, including knowingly and willfully joining into the unlawful agreement. (See doc.

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Bluebook (online)
Sanchez v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanchez-v-united-states-txnd-2024.