Santana-Zapata v. USA

2015 DNH 200
CourtDistrict Court, D. New Hampshire
DecidedOctober 28, 2015
Docket15-cv-016-LM
StatusPublished

This text of 2015 DNH 200 (Santana-Zapata v. USA) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Santana-Zapata v. USA, 2015 DNH 200 (D.N.H. 2015).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Deybi Wagner Santana-Zapata

v. Civil No. 15-cv-016-LM Opinion No. 2015 DNH 200 United States of America

O R D E R

Deybi Wagner Santana-Zapata pleaded guilty in this court to

one count of reentry after deportation and was sentenced to 46

months in prison. He now moves pursuant to 28 U.S.C. § 2255 to

withdraw his guilty plea and vacate his sentence. The court

appointed counsel to represent him and, on October 23, 2015,

held an evidentiary hearing. For the reasons that follow, the

court denies Santana-Zapata’s motion.

Background

In March 2014, a grand jury indicted Santana-Zapata on one

count of reentry after deportation, in violation of 8 U.S.C.

§§ 1326(a) and (b)(2). Cr. doc. no. 7.1 On June 10, 2014,

Santana-Zapata pleaded guilty. At his change of plea hearing,

Santana-Zapata stated that he understood that he was subject to

1 “Cr. doc. no.” refers to document numbers in the docket of the underlying criminal proceeding (No. 14-cr-024-LM). “Doc. no.” refers to document numbers in the instant proceeding. a maximum sentence of 20 years in prison. At his sentencing

hearing on September 29, 2014, the court calculated Santana-

Zapata’s guideline range to be 46-57 months of imprisonment.

Santana-Zapata’s counsel, Jonathan Saxe, argued for 24 months;

the prosecutor argued for 46 months. The court sentenced

Santana-Zapata to a 46–month prison term. Cr. doc. no. 25.

On January 13, 2015, Santana-Zapata filed a motion to

vacate his sentence, arguing that his lawyer was ineffective for

several reasons, primarily for failing to advocate for a

downward departure under United States Sentencing Guideline §

5K3.1, the fast track program for illegal reentry cases. In an

order dated March 18, 2015, the court found Santana-Zapata’s

contention with respect to the fast track program meritless and

unworthy of an evidentiary hearing for the reasons stated in the

government’s objection. Doc. no. 5. The court appointed a

lawyer for Santana-Zapata and held in abeyance a ruling on

whether an evidentiary hearing was necessary to resolve Santana-

Zapata’s other ineffective assistance of counsel claims until

the lawyer had an opportunity to review the case.

On June 23, 2015, Santana-Zapata filed a supplement to his

§ 2255 motion, doc. no. 9, in which he asserts three claims of

ineffective assistance of counsel. First, he argues that his

plea was not knowing and voluntary because he entered the plea

2 on his counsel’s assurance that the government would “go light”

on him at the sentencing hearing. Second, he argues that his

counsel failed to object to his Presentence Report (“PSR”) on

the basis of Apprendi v. New Jersey, 530 U.S. 466 (2000),

thereby subjecting him to a 20-year maximum sentence. Third, he

argues that his counsel failed to file a notice of appeal on his

behalf.2 The government objects. Doc. nos. 4 & 11.

By order dated September 2, 2015, the court scheduled a

hearing to resolve factual disputes on the first and third

claims.

Analysis

Under § 2255, a federal prisoner may ask the court to

vacate, set aside or correct a sentence on “the ground that the

sentence was imposed in violation of the Constitution or laws of

the United States, or that the court was without jurisdiction to

impose such sentence, or that the sentence was in excess of the

maximum authorized by law or is otherwise subject to collateral

attack.” 28 U.S.C. § 2255(a). When the prisoner's claims are

2 Santana-Zapata asserts a host of other ineffectiveness claims in his § 2255 filings, including that his counsel did not consult with him prior to sentencing, did not investigate mitigation evidence, and did not assert mitigation arguments at his sentencing hearing. At the October 23 evidentiary hearing, however, Santana-Zapata limited the claims currently before the court to only those claims asserted in his supplement (doc. no. 9).

3 based on ineffective assistance of counsel, as they are here,

the prisoner “must demonstrate both: (1) that counsel’s

performance was deficient, meaning that counsel made errors so

serious that counsel was not functioning as the ‘counsel’

guaranteed the defendant by the Sixth Amendment; and (2) that

the deficient performance prejudiced the defense.” Rossetti v.

United States, 773 F.3d 322, 327 (1st Cir. 2014) (internal

quotation marks omitted), cert. denied, 135 S. Ct. 1751 (2015)

(citing Strickland v. Washington, 466 U.S. 668, 687 (1984)). A

failure to meet either the deficiency or prejudice prong will

defeat an ineffective assistance of counsel claim. Strickland,

466 U.S. at 697.

The burden on a prisoner who alleges that counsel rendered

constitutionally inadequate representation is “highly demanding”

and “heavy.” Knight v. Spencer, 447 F.3d 6, 15 (1st Cir. 2006)

(quoting Williams v. Taylor, 529 U.S. 362, 393 (2000)).

In assessing the adequacy of appointed counsel, [the court] indulge[s] a strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance, . . . finding deficiency only where, given the facts known to counsel at the time, counsel's choice was so patently unreasonable that no competent attorney would have made it . . . . And, to establish prejudice, a defendant must demonstrate a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different.

4 Rossetti, 773 F.3d at 327 (internal quotation marks and

citations omitted). To establish prejudice with respect to a

sentencing hearing, a petitioner must show “that but for his

counsel’s deficiency, there is a reasonable probability that he

would have received a different sentence.” Peralta v. United

States, 597 F.3d 74, 79 (1st Cir. 2010) (internal quotation

marks omitted).

The court may either summarily dismiss a prisoner’s § 2255

claim or grant an evidentiary hearing to determine if it is

meritorious. 28 U.S.C. § 2255(b) provides that:

Unless the motion and the files and records of the case conclusively show that the prisoner is entitled to no relief, the court shall cause notice thereof to be served upon the United States attorney, grant a prompt hearing thereon, determine the issues and make findings of fact and conclusions of law with respect thereto.

In evaluating whether an evidentiary hearing is required,

the court “take[s] as true the sworn allegations of fact set

forth in the petition unless those allegations are merely

conclusory, contradicted by the record, or inherently

incredible.” Owens v.

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Related

Peralta v. United States
597 F.3d 74 (First Circuit, 2010)
Padilla v. Kentucky
559 U.S. 356 (Supreme Court, 2010)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Almendarez-Torres v. United States
523 U.S. 224 (Supreme Court, 1998)
Roe v. Flores-Ortega
528 U.S. 470 (Supreme Court, 2000)
Apprendi v. New Jersey
530 U.S. 466 (Supreme Court, 2000)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Knight v. United States
37 F.3d 769 (First Circuit, 1994)
Hernandez v. Reno
238 F.3d 50 (First Circuit, 2001)
Knight v. Spencer
447 F.3d 6 (First Circuit, 2006)
Owens v. United States
483 F.3d 48 (First Circuit, 2007)
Moreno-Espada v. United States
666 F.3d 60 (First Circuit, 2012)
Jesus Miranda-Gonzalez v. United States
181 F.3d 164 (First Circuit, 1999)
Rossetti v. United States
773 F.3d 322 (First Circuit, 2014)
United States v. Jimenez-Banegas
790 F.3d 253 (First Circuit, 2015)

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2015 DNH 200, Counsel Stack Legal Research, https://law.counselstack.com/opinion/santana-zapata-v-usa-nhd-2015.