United States v. Miguel Galvez-Morales

538 F. App'x 547
CourtCourt of Appeals for the Fifth Circuit
DecidedAugust 15, 2013
Docket12-10691
StatusUnpublished

This text of 538 F. App'x 547 (United States v. Miguel Galvez-Morales) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth 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. Miguel Galvez-Morales, 538 F. App'x 547 (5th Cir. 2013).

Opinion

PER CURIAM: *

Defendant-Appellant Miguel Galvez-Morales (“Galvez-Morales”) pleaded guilty to illegal reentry following deportation in violation of 8 U.S.C. § 1326(a) and was sentenced to 30 months’ imprisonment. He appeals the eight-level sentence enhancement he received pursuant to U.S.S.G. § 2L1.2(b)(l)(C) for having previously committed an aggravated felony. Because Galvez-Morales’ 2010 Texas conviction for assault of a public servant is properly classified as a crime of violence and therefore as an aggravated felony under § 2L1.2(b)(1)(C), we affirm his sentence.

I.

In 2010, Galvez-Morales pleaded guilty in Texas to assault of a public servant. A person commits the Texas offense of assault “if the person intentionally, knowingly, or recklessly causes bodily injury to another, including the person’s spouse.” Tex. Penal Code Ann. § 22.01(a)(1). The offense is a felony of the third degree, inter alia, “if the offense is committed against a person the actor knows is a public servant while the public servant is lawfully discharging an official duty.” Id. § 22.01(b)(1). Galvez-Morales’ Texas indictment charged that on or about December 3, 2009, he

did unlawfully ... intentionally, knowingly and recklessly cause bodily injury to [the victim] by STRIKING [the victim] WITH DEFENDANT’S HAND and [the victim] was at the time of said offense a public servant, namely: a DALLAS POLICE OFFICER, engaged in the lawful discharge of an official duty and [Galvez] knew that [the victim] was a public servant.

In his judicial confession, Galvez-Morales admitted that he committed the offense “exactly as alleged in the indictment in this cause.”

On December 20, 2011, Galvez-Morales was arrested by immigration authorities and charged with illegal reentry following deportation in violation of 8 U.S.C. § 1326. Galvez-Morales pleaded guilty. The pre-sentence report recommended an eight-level sentence enhancement pursuant to U.S.S.G. § 2L1.2(b)(l)(C) for Galvez-Mor-ales’ 2010 Texas conviction for assault of a public servant. The district court agreed, overruling Galvez-Morales’ objection. The district court sentenced Galvez-Morales to 30 months’ imprisonment.

II.

Galvez-Morales now appeals the district court’s application of the eight-level enhancement to his sentence. We review de novo whether the district court properly categorized a prior offense as an aggravated felony. See United States v. Flores-Gallo, 625 F.3d 819, 821 (5th Cir.2010). Where, as in the present case, the statute of conviction defines multiple offenses, at least one of which does not describe an aggravated felony, we apply a modified *549 categorical approach. United States v. Medina-Torres, 703 F.3d 770, 774 (5th Cir.2012). Under the modified categorical approach, we may examine the charging document, written plea agreement, transcript of a plea colloquy, or any explicit factual finding by the trial judge to which the defendant assented, in order “to determine whether the guilty plea conviction ‘necessarily’ fell under a particular subsection of the statute that meets the aggravated felony criterion.” Rodriguez v. Holder, 705 F.3d 207, 210-11 (5th Cir.2013).

Pursuant to § 2L1.2(b)(l)(C), a defendant convicted of illegal reentry receives an eight-level sentencing enhancement when the defendant was previously deported after a conviction for an aggravated felony. The term “aggravated felony” has the meaning given to the term in 8 U.S.C. § 1101(a)(43). U.S. Sentencing Guidelines Manual § 2L1.2(b)(l)(C) cmt. 3. Section 1101(a)(43) defines aggravated felony as, inter alia, “a crime of violence (as defined in section 16 of Title 18, but not including a purely political offense) for which the term of imprisonment is at least one year.” 8 U.S.C. § 1101(a)(43)(F). Section 16 defines a crime of violence as:

(a) an offense that has as an element the use, attempted use, or threatened use of physical force against the person or property of another, or
(b) any other offense that is a felony and that, by its nature, involves a substantial risk that physical force against the person or property of another may be used in the course of committing the offense.

18 U.S.C. § 16. The Texas offense of assault does not satisfy § 16(a) because it does not have the use, attempted use, or threatened use of physical force as an element. See United States v. Villegas-Her-nandez, 468 F.3d 874, 878-79 (5th Cir. 2006). Therefore, Galvez-Morales’ offense will qualify as an aggravated felony only if it constitutes a crime of violence under § 16(b).

“Section 16(b) encompasses crimes that, while capable of being committed without the use of physical force, always entail a substantial risk that physical force—defined as ‘destructive or violent force’—may be used.” Rodriguez, 705 F.3d at 213 (quoting Larin-Ulloa v. Gonzales, 462 F.3d 456, 465 (5th Cir.2006)). “A ‘substantial risk requires a strong probability that the application of physical force during the commission of a crime will occur.’ ” United States v. Landeros-Gonzales, 262 F.3d 424, 427 (5th Cir.2001) (quoting United States v. Rodriguez-Guzman, 56 F.3d 18, 20 (5th Cir.1995)). “Section 16(b) sweeps more broadly than § 16(a).” Leocal v. Ashcroft, 543 U.S. 1, 10, 125 S.Ct. 377, 160 L.Ed.2d 271 (2004). It “covers offenses that naturally involve a person acting in disregard of the risk that physical force might be used against another in committing an offense.” Id. It does not, however, encompass merely negligent conduct. Id.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Rodriguez-Guzman
56 F.3d 18 (Fifth Circuit, 1995)
United States v. Landeros-Gonzalez
262 F.3d 424 (Fifth Circuit, 2001)
Perez-Munoz v. Keisler
507 F.3d 357 (Fifth Circuit, 2007)
Leocal v. Ashcroft
543 U.S. 1 (Supreme Court, 2004)
James v. United States
550 U.S. 192 (Supreme Court, 2007)
United States v. Efren Villegas-Hernandez
468 F.3d 874 (Fifth Circuit, 2006)
Esau Rodriguez v. Eric Holder, Jr.
705 F.3d 207 (Fifth Circuit, 2013)
United States v. Flores-Gallo
625 F.3d 819 (Fifth Circuit, 2010)
United States v. Cesar Medina-Torres
703 F.3d 770 (Fifth Circuit, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
538 F. App'x 547, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-miguel-galvez-morales-ca5-2013.