State of Washington v. Juan Manuel Flores-Arroyo

CourtCourt of Appeals of Washington
DecidedMay 12, 2020
Docket36392-9
StatusUnpublished

This text of State of Washington v. Juan Manuel Flores-Arroyo (State of Washington v. Juan Manuel Flores-Arroyo) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Washington v. Juan Manuel Flores-Arroyo, (Wash. Ct. App. 2020).

Opinion

FILED MAY 12, 2020 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

STATE OF WASHINGTON, ) ) No. 36392-9-III Respondent, ) ) v. ) ) JUAN MANUEL FLORES-ARROYO, ) UNPUBLISHED OPINION ) Appellant. )

KORSMO, J. — Juan Flores-Arroyo appeals the denial of his motion to withdraw

his guilty plea. He argues that he received ineffective assistance of counsel and that the

court erred in excluding evidence offered to attack his plea counsel’s credibility. We

affirm.

FACTS

Mr. Flores-Arroyo came to the United States on a tourist visa in 2013 and

overstayed the visa limit. In 2017, he was charged in Chelan County with drive-by

shooting, possession of methamphetamine, and alien in possession of a firearm. Mr.

Flores-Arroyo’s family hired George Trejo to represent Mr. Flores-Arroyo. Mr. Trejo

negotiated an agreement for Flores-Arroyo to plead guilty solely to drive-by shooting

with a low end sentence recommendation. Mr. Trejo advised Mr. Flores-Arroyo that No. 36392-9-III State v. Flores-Arroyo

immigration consequences were possible and that he likely would be deported if federal

authorities commenced immigration proceedings. Mr. Flores-Arroyo acknowledged on

the record that he could face immigration consequences from his plea. The court

accepted the plea after verifying that it was knowingly and voluntarily entered.

Immigration authorities commenced deportation proceedings after Mr. Flores-

Arroyo completed his sentence. An immigration judge determined that the drive-by

shooting constituted a “particularly serious crime” for immigration purposes and ordered

his deportation. Mr. Flores-Arroyo appealed the immigration decision.

While that appeal was underway, Mr. Flores-Arroyo also filed a CrR 7.8 motion to

withdraw his guilty plea in Chelan County Superior Court. He argued that he received

ineffective assistance of plea counsel because his attorney failed to adequately advise him

about immigration consequences. He also asserted that he would have accepted a longer

prison time in order to avoid deportation. The court conducted a hearing on the motion.

Mr. Flores-Arroyo sought to call a past client of Mr. Trejo to testify that he had received

incorrect immigration advice. The trial court found the testimony irrelevant to whether

Mr. Flores-Arroyo received proper advice. The court also disallowed evidence of

counsel’s bar discipline history.

The trial court denied the CrR 7.8 motion because it found Mr. Flores-Arroyo was

adequately advised about immigration consequences before entering his plea. The court

further noted that, of the three charges Mr. Flores-Arroyo faced, the drive-by shooting

2 No. 36392-9-III State v. Flores-Arroyo

charge carried the least certain immigration consequences. Mr. Trejo correctly advised

his client that deportation was likely.

Mr. Flores-Arroyo timely appealed the trial court’s denial of his motion. A panel

considered his appeal without hearing argument.

ANALYSIS

The appeal presents two arguments. We first address whether the trial court erred

in denying the motion to withdraw the guilty plea before turning to the contention that the

court erred when it rejected impeachment evidence.

Ineffective Assistance of Counsel

We review the trial court’s decision whether to allow withdrawal of a guilty plea

for abuse of discretion. State v. Quy Dinh Nguyen, 179 Wn. App. 271, 281-282, 319 P.3d

53 (2013). The trial court may allow withdrawal of a guilty plea to correct a manifest

injustice, including ineffective assistance of counsel. Id. at 282.

A defendant who claims ineffective assistance must establish that counsel’s

performance was deficient and prejudicial. State v. Sandoval, 171 Wn.2d 163, 170, 249

P.3d 1015 (2011). Prejudice is established if the defendant can demonstrate that, but for

counsel’s errors, there was a reasonable probability he would have gone to trial rather

than plead guilty. Id. at 174-175.

3 No. 36392-9-III State v. Flores-Arroyo

Defense counsel must advise a client about the consequences of pleading guilty.

In re Ramos, 181 Wn. App. 743, 749-750, 326 P.3d 826 (2014). Counsel must provide

accurate information about potential immigration ramifications, even though the relevant

law is often unclear. Id. at 750-751. Subsequent to Padilla v. Kentucky1, counsel must

appropriately advise a client when federal law classifies the defendant’s offense as clearly

deportable. Id. at 751. If immigration consequences for the offense are not clear, counsel

must provide a general warning that immigration consequences are possible. Id. at 752.

Contradictory or wavering warnings about deportation are disfavored because they

decrease the likelihood that a defendant will appreciate the potential consequences. State

v. Manajares, 197 Wn. App. 798, 807, 391 P.3d 530 (2017).

Both parties acknowledge Washington’s drive-by shooting offense does not have

clear federal deportation consequences, while possession of methamphetamine and alien

in possession of a firearm have clear negative consequences. Mr. Trejo correctly

informed Mr. Flores-Arroyo that he could face immigration consequences, including

possible deportation, if he chose to plead guilty to drive-by shooting. This advice was

accurate and sufficient for an offense with unclear immigration consequences. Had Mr.

Flores-Arroyo pleaded guilty to his other two offenses or been convicted for these

offenses, his immigration consequences were likely far worse. While Mr. Flores-Arroyo

1 Padilla v. Kentucky, 559 U.S. 356, 130 S. Ct. 1473, 176 L. Ed. 2d 284 (2010).

4 No. 36392-9-III State v. Flores-Arroyo

now argues he would prefer to go to trial, he does not argue that he had any likelihood of

success at trial. Conviction for any of his charged offenses would still carry immigration

consequences regardless of his sentence duration.

Mr. Trejo gave his client accurate and adequate advice prior to pleading guilty.

Counsel was not ineffective for negotiating a relatively favorable deal under the

circumstances. Mr. Flores-Arroyo has not met his heavy burden of establishing that

counsel provided ineffective assistance. Accordingly, the trial court did not abuse its

discretion by denying the motion to withdraw the plea.

Impeachment Evidence

This court reviews evidentiary rulings for abuse of discretion. Peralta v. State,

187 Wn.2d 888, 894, 389 P.3d 596 (2017). A trial court abuses its discretion when it

applies the wrong legal standard. Gilmore v. Jefferson County Pub. Transp. Benefit Area,

190 Wn.2d 483, 499, 415 P.3d 212 (2018). Evidentiary errors are not presumptively

prejudicial and we will only reverse when the appellant establishes the error affected the

outcome. State v. Barry, 183 Wn.2d 297, 303, 313, 352 P.3d 161 (2015).

A witness may not be impeached on a collateral matter. State v. Oswalt, 62 Wn.2d

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Related

Padilla v. Kentucky
559 U.S. 356 (Supreme Court, 2010)
State v. Oswalt
381 P.2d 617 (Washington Supreme Court, 1963)
State v. Sandoval
249 P.3d 1015 (Washington Supreme Court, 2011)
State v. Fankhouser
138 P.3d 140 (Court of Appeals of Washington, 2006)
State of Washington v. Jose Antonio Manajares
391 P.3d 530 (Court of Appeals of Washington, 2017)
Gilmore v. Jefferson County Pub. Transp. Benefit Area
415 P.3d 212 (Washington Supreme Court, 2018)
Harbottle v. Braun
447 P.3d 654 (Court of Appeals of Washington, 2019)
State v. Sandoval
171 Wash. 2d 163 (Washington Supreme Court, 2011)
State v. Barry
352 P.3d 161 (Washington Supreme Court, 2015)
Peralta v. State
389 P.3d 596 (Washington Supreme Court, 2017)
State v. Fankhouser
138 P.3d 140 (Court of Appeals of Washington, 2006)
State v. Quy Dinh Nguyen
319 P.3d 53 (Court of Appeals of Washington, 2013)
State v. Ramos
181 Wash. App. 743 (Court of Appeals of Washington, 2014)

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