United States v. Rios

201 F. Supp. 3d 1266, 2016 U.S. Dist. LEXIS 115578, 2016 WL 4472996
CourtDistrict Court, E.D. Washington
DecidedAugust 12, 2016
DocketNo. 2:13-CR-02059-RHW
StatusPublished
Cited by3 cases

This text of 201 F. Supp. 3d 1266 (United States v. Rios) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Rios, 201 F. Supp. 3d 1266, 2016 U.S. Dist. LEXIS 115578, 2016 WL 4472996 (E.D. Wash. 2016).

Opinion

ORDER GRANTING DEFENDANT’S 28 U.S.C. § 2255 MOTION TO VACATE SENTENCE AND FOR RE-SENTENCING

U.S. MARSHALS SERVICE ACTION REQUIRED

ROBERT H. WHALEY, Senior United States District Judge

Before the Court is Defendant Christo-bal Miguel Rios’s 28 U.S.C. § 2255 Motion to Vacate Sentence and for Resentencing, ECF No. 49. Having reviewed the motions and all relevant filings, the Court is fully informed.

BACKGROUND

On April 9, 2013, a grand jury returned a single-count indictment charging Mr. Rios -with possession of a firearm by a prohibited person, in violation of 18 U.S.C. § 922(g). Mr. Rios pled guilty to the one-count indictment, a felon in possession charge, on June 4, 2013. The written plea agreement provided that the parties “believed” Mr. Rios was subject to a Base Offense Level of 20 pursuant to U.S. Sentencing Guidelines Manual (“U.S.S.G.”) § 2K2.1 (2015), and would jointly recommend a sentence of 60 months imprisonment. The agreement also contains express waivers of Mr. Rios’s rights to appeal and file motions under 28 U.S.C. § 2255.

Mr. Rios’s Presentence Investigation Report advised that Mr. Rios qualified for an enhanced Base Offense Level of 20 pursuant to U.S.S.G. § 2K2.1(a)(4)(A) because his 2009 conviction for residential burglary qualified as a crime of violence under U.S.S.G. § 4B1.2(a)(2). Probation also recommended a three-point reduction in offense level for acceptance of responsibility, 'resulting in a Total Offense Level of 17. •

[1270]*1270At the October 1, 2013 sentencing hearing, the Court adopted the Presentence Investigation Report without change and sentenced Mr. Rios to the agreed upon 60 month term of incarceration. The Judgment issued on October 4, 2013. Mr. Rios did not file an appeal. On May 4, 2016, Mr. Rios filed the instant motion to vacate his sentence pursuant to 28 U.S.C. § 2255, arguing that the Supreme Court’s decision in Johnson v. United States, — U.S. —, 135 S.Ct. 2551, 192 L.Ed.2d 569 (2015), which invalidated the residual clause of the Armed Career Criminal Act (“ACCA”), likewise invalidated the residual clause contained in U.S.S.G. § 4B1.2(a)(2).

On June 27, 2016, after briefing on Mr. Rios’s motion was completed, the Supreme Court granted certiorari in Beckles v. United States, — U.S. —, 136 S.Ct. 2510, 195 L.Ed.2d 838 (2016), which is slated to answer the key question presented by Mr. Rios’s motion: whether the Supreme Court’s decision in Johnson applies retroactively to cases on collateral review challenging federal sentences enhanced under the residual clause in U.S.S.G. § 4B1.2(a)(2). Shortly thereafter, on July 5, 2016, the Court struck the hearing date on Mr. Rios’s motion and requested supplemental briefing on whether a stay pending Bedeles was appropriate. Having concluded that a stay would be improper, the Court issues the following Order.

DISCUSSION

I. Legal Standard

A. 28 U.S.C. § 2255

28 U.S.C. § 2255 outlines four grounds upon which a Court may grant relief to a prisoner who challenges his sentence: (1) “that the sentence was imposed in violation of the Constitution or laws of the United States;” (2) “that the court was without jurisdiction to impose such sentence;” (3) “that the sentence was in excess of the maximum authorized by law;” and (4) that the sentence is otherwise “subject to collateral attack.” 28 U.S.C. § 2255(a). Although there are four categories, the range of claims that fall within the scope of § 2255 are narrow. United States v. Wilcox, 640 F.2d 970, 972 (9th Cir.1981). Ordinarily, the asserted error of law must be “a fundamental defect which inherently results in a complete miscarriage of justice.” Davis v. United States, 417 U.S. 333, 346, 94 S.Ct. 2298, 41 L.Ed.2d 109 (1974) (quoting Hill v. United States, 368 U.S. 424, 429, 82 S.Ct. 468, 7 L.Ed.2d 417 (1962)).

B. The U.S.S.G. § 2K2.1 Enhancement

Pursuant to U.S.S.G. § 2K2.1, a defendant convicted of unlawful possession of a firearm is subject to an enhanced Base Offense Level of 20 if he or she has a prior felony conviction for either a “crime of violence” or a “controlled substance offense.” See U.S.S.G. § 2K2.1(a)(4)(A). The Guidelines define crime of violence to include any crime punishable by imprisonment for a term exceeding one year that:

(1) has as an element the use, attempted use, or threatened use of physical force against the person of another; or
(2) is burglary of a dwelling, arson, or extortion, involves use of explosives, or otherwise involves conduct that ;presents a serious potential risk of physical injury to another.

U.S.S.G. § 4B1.2(a) (emphasis added).

The italicized language in U.S.S.G. § 4B1.2(a)(2) is commonly known as the “residual clause.” In Johnson v. United States, the Supreme Court held that the identically worded “residual clause” of the ACCA, 18 U.S.C. 924(e)(2)(B)(ii), violates a defendant’s right to due process because it is unconstitutionally vague. 135 S.Ct. at 2560. Generally, the residual clauses in the ACCA and U.S.S.G. § 4B1.2(a)(2) are interpreted according to the same precedent. [1271]*1271See United States v. Coronado, 603 F.3d 706, 709-11 (9th Cir.2010).

II. Analysis

Mr. Ribs argues that “it follows from Johnson” that the residual clause in the Guidelines is, likewise, unconstitutionally vague. Because Johnson operated to invalidate the residual clause language in U.S.S.G. § 4B1.2(a)(2), Mr. Rios contends, an offense can only qualify as a “crime of violence” under the Guidelines if it falls within either U.S.S.G. § 4B1.2(a)(l) (the “elements clause) or the. first clause of U.S.S.G. § 4B1.2(a)(2) .(the “enumerated offenses clause”). Mr. .Rios claims that post-Johnson, his residential burglary conviction no longer qualifies as a crime of violence and accordingly, that his 60-month sentence is in violation of the law.

The government opposes Mr. Rios’s motion on two independent grounds. First, the government contends that the Court should enforce Mr.

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Bluebook (online)
201 F. Supp. 3d 1266, 2016 U.S. Dist. LEXIS 115578, 2016 WL 4472996, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-rios-waed-2016.