United States v. Harjit Johal

CourtCourt of Appeals for the Ninth Circuit
DecidedApril 16, 2021
Docket19-17244
StatusUnpublished

This text of United States v. Harjit Johal (United States v. Harjit Johal) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Harjit Johal, (9th Cir. 2021).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS APR 16 2021 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATES OF AMERICA, No. 19-17244

Plaintiff-Appellee, D.C. Nos. 2:19-cv-00597-GEB 2:14-cr-00169-GEB- v. DB-3

HARJIT JOHAL, MEMORANDUM* Defendant-Appellant.

Appeal from the United States District Court for the Eastern District of California Garland E. Burrell, Jr., District Judge, Presiding

Argued and Submitted March 1, 2021 San Francisco, California

Before: WARDLAW and BERZON, Circuit Judges, and CHEN,** District Judge.

Harjit Johal, a legal permanent resident, appeals the district court’s denial of

her 28 U.S.C. § 2255 motion to vacate her conviction. We granted a certificate of

appealability with respect to the following issue: whether defense counsel rendered

ineffective assistance by failing to accurately advise Johal about adverse

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The Honorable Edward M. Chen, United States District Judge for the Northern District of California, sitting by designation. immigration consequences. For the reasons that follow, we vacate the conviction

and remand to the district court.

To vacate her conviction on the basis of ineffective assistance of counsel,

Johal must show (1) that defense counsel’s representation “fell below an objective

standard of reasonableness” and (2) “a reasonable probability that, but for

counsel’s unprofessional errors, the result of the proceeding would have been

different.” Strickland v. Washington, 466 U.S. 668, 688, 694 (1984). “A

‘reasonable probability’ is a standard of proof . . . ‘somewhat lower’ than a

preponderance of the evidence.” United States v. Rodriguez-Vega, 797 F.3d 781,

788 (9th Cir. 2015) (quoting Strickland, 466 U.S. at 694)). “[T]he performance and

prejudice components of the ineffectiveness inquiry are mixed questions of law

and fact,” Strickland, 466 U.S. at 698, and so are reviewed de novo, United States

v. Birtle, 792 F.2d 846, 847 (9th Cir. 1986) (citing Strickland, 466 U.S. at 698).

1. On the current record, defense counsel’s performance “fell below an

objective standard of reasonableness.” Strickland, 466 U.S. at 688. On more than

one occasion, defense counsel informed Johal that “should a jury find her

guilty . . . she would be deportable,” when in fact she could have avoided removal

despite being convicted by obtaining a sentence of imprisonment of less than one

year.

Johal was charged with making a false declaration to a federal grand jury, in

2 violation of 18 U.S.C. § 1623. While “[a]ny alien who is convicted of an

aggravated felony at any time after admission is deportable,” 8 U.S.C. §

1227(a)(2)(A)(iii), “[t]he term ‘aggravated felony’ means . . . an offense relating to

. . . perjury . . . for which the term of imprisonment is at least one year.” Id. at §

1101(a)(43)(S) (emphasis added).

Section 1623 carries a potential sentence of imprisonment of up to five

years. But the statutory definition of “term of imprisonment” for purposes of an

aggravated felony is deemed to include “the period of incarceration . . . ordered by

a court of law.” 8 U.S.C. § 1101(a)(48)(B). So the relevant metric is the term to

which a defendant is actually sentenced, not the maximum sentence. See, e.g.,

Renteria-Morales v. Mukasey, 551 F.3d 1076, 1089 (9th Cir. 2008) (explaining

that “because [petitioner] was actually sentenced to a term of imprisonment of at

least one year, the requirements of § 1101(a)(43)(S) have been met”).

The government argues that defense counsel’s advice was accurate (and

therefore not deficient) because the Guidelines sentence for Johal’s offense was

more than one year. But judges are not bound to impose Guidelines sentences.

United States v. Booker, 543 U.S. 220, 264 (2005). And, for the reasons given

below, it is likely that Johal’s actual sentence would have fallen below the

Guidelines range had she pled guilty to the charged offense.

“[W]hen, the deportation consequence is truly clear, as it was here, the duty

3 to give correct advice is equally clear.” Padilla v. Kentucky, 559 U.S. 356, 357

(2010). As Johal’s lawyer was indisputably wrong in telling her that she would

necessarily be deportable if convicted of any felony, or of the felony with which

she was charged, he provided ineffective assistance of counsel.1

2. There is “a reasonable probability that, but for counsel’s unprofessional

errors, the result of the proceeding would have been different.” Strickland, 466

U.S. at 694.2

Johal declares that “[i]f [she] had properly understood the immigration

consequences of the charges against [her], [she] would not have taken [her] case to

trial.” If Johal had instead pled guilty, she would have likely faced a Guidelines

sentence of 15 to 21 months’ imprisonment (given the three-level reduction in

offense level for acceptance of responsibility, see U.S.S.G. § 3E1.1 & cmt.3),

rather than 24 to 30 months, making an ultimate sentence of less than 12 months

1 To the extent that, as the government argues, a conviction for 18 U.S.C. § 1623 would not necessarily fall within the definition of perjury, defense counsel’s advice was all the worse, as counsel informed Johal that she was charged with a deportable offense, although she may not have been. 2 Although the parties interpret this standard to mean that Johal must show a “reasonable probability” of receiving a sentence of less than one year, the Supreme Court has suggested that Johal could succeed by demonstrating only a “reasonable probability” of receiving a lesser sentence than she did. See Lee v. United States, 137 S. Ct. 1958, 1968-69 (2017) (defendant who pled guilty based on erroneous advice of counsel was prejudiced even though he had “no viable defense”); Lafler v. Cooper, 566 U.S. 156, 161, 164 (2012). Because Johal can satisfy the parties’ stricter interpretation, we need not address this distinction.

4 much more likely. Further, Johal declares that, had she received accurate advice

from her attorney, she “would have sought a plea agreement for less than one year,

offered to cooperate with the government’s investigation, and pled guilty to secure

the lowest possible sentence.”

The government argues that no plea offer was actually made and that, if an

offer had been available, there is no evidence that the government would have

supported a sentence of less than one year. But some plea offer quite probably

would have been available. Emails between the government and defense counsel

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Related

Padilla v. Kentucky
559 U.S. 356 (Supreme Court, 2010)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
United States v. Booker
543 U.S. 220 (Supreme Court, 2004)
Barber v. Thomas
560 U.S. 474 (Supreme Court, 2010)
United States v. Claude S. Birtle
792 F.2d 846 (Ninth Circuit, 1986)
Lafler v. Cooper
132 S. Ct. 1376 (Supreme Court, 2012)
Renteria-Morales v. Mukasey
551 F.3d 1076 (Ninth Circuit, 2008)
United States v. Elizabeth Rodriguez-Vega
797 F.3d 781 (Ninth Circuit, 2015)
Jae Lee v. United States
582 U.S. 357 (Supreme Court, 2017)
Michael White v. Charles Ryan
895 F.3d 641 (Ninth Circuit, 2018)
George Kayer v. Charles L. Ryan
923 F.3d 692 (Ninth Circuit, 2019)
Shinn v. Kayer
592 U.S. 111 (Supreme Court, 2020)

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