United States v. Sergio Murillo

927 F.3d 808
CourtCourt of Appeals for the Fourth Circuit
DecidedJune 24, 2019
Docket18-6844
StatusPublished
Cited by21 cases

This text of 927 F.3d 808 (United States v. Sergio Murillo) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth 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. Sergio Murillo, 927 F.3d 808 (4th Cir. 2019).

Opinions

THACKER, Circuit Judge:

On March 24, 2016, a grand jury indicted Sergio Carrillo Murillo ("Appellant") for conspiracy to distribute and possession with intent to distribute cocaine. Three months later, Appellant pled guilty to conspiracy to distribute cocaine, in violation of 21 U.S.C. §§ 841 (a)(1) and 846.

Following his arrest, and throughout the plea negotiation process, Appellant's purported primary concern was the impact a criminal conviction could have on his status as a lawful permanent resident of the United States. His attorney advised him that, if he pled guilty to the lesser included offense, deportation was a mere possibility that he could fight in immigration court. But Appellant's attorney was wrong: conspiracy to distribute cocaine is an "aggravated felony" under the Immigration and Nationality Act, see 8 U.S.C. § 1101 (a)(43)(B), and a noncitizen convicted of such a crime is subject to mandatory deportation, see id. § 1227(a)(2)(A)(iii).

On September 7, 2017, Appellant moved under 28 U.S.C. § 2255 to vacate his conviction on the ground that he received ineffective assistance of counsel in violation of the Sixth Amendment. The district court denied his motion, and Appellant appealed. For the reasons that follow, we reverse the decision of the district court and remand for further proceedings.

I.

In 1995, when Appellant was seven years old, he and his family moved from Mexico to the United States. Appellant has lived in the United States ever since. Today, Appellant is a lawful permanent resident. He no longer has family in Mexico, and he is engaged to be married to an American citizen. As such, "[s]taying in the United States with [his] family has always been [his] number one priority." J.A. 65. 1

Twenty-one years after he came to the United States, Appellant got into some legal trouble. On February 10, 2016, Appellant traveled with another man from New Mexico to Virginia to sell a kilogram of cocaine. Unknowingly, the pair sold the drugs to a confidential informant. The confidential informant recorded the transaction while law enforcement officers observed it. After the exchange, Appellant was arrested. On March 24, 2016, a grand jury indicted Appellant on two counts of cocaine-related offenses: (1) conspiracy to distribute in violation of 21 U.S.C. §§ 841 (a) and 846 ; and (2) possession with intent to distribute in violation of 21 U.S.C. § 841 (a)(1) and 18 U.S.C. § 2 .

Shortly after his arrest, Appellant retained attorney Katherine Martell ("Martell") to represent him. Given his circumstances, Appellant wanted an attorney with immigration law experience, and he had heard Martell touting her knowledge of immigration law on Spanish radio. 2

On Appellant's behalf, Martell negotiated a plea agreement with the Government. The Government offered to drop the possession with intent to distribute charge if Appellant would plead guilty to the conspiracy charge. That deal allowed Appellant to avoid a mandatory minimum sentence of five years. See 21 U.S.C. § 841 (b)(1)(B)(ii). After discussing a draft of the plea agreement with Appellant, Martell noted in the margin of the draft, "Ask to omit immigration waivers." J.A. 109. Specifically, Martell sought to omit five immigration-related clauses from the draft:

• (1) "Consent Given for Removal from the United States" (which would have required Appellant not to contest removal proceedings brought against him);
• (2) "Waiver of Rights Related to Removal from the United States" (which would have required Appellant to waive his rights to apply for all forms of relief or protection from removal or deportation);
• (3) "Exception for Changed Circumstances Arising After Plea" (which would have allowed Appellant to apply for asylum, withholding of removal, or protection under Article 3 of the Convention Against Torture based only on circumstances arising after the entry of his plea);
• (4) "Abandonment of Pending Applications for Relief from Removal" (which would have required Appellant to abandon any existing immigration benefit he holds or any pending application for relief from removal or deportation); and
• (5) "The Defendant's Cooperation in the Defendant's Removal" (which would have required Appellant to agree to assist the Department of Homeland Security in any future removal proceedings). Id. at 108-10 .

Indeed, Martell successfully negotiated with the Government to omit from the final plea agreement those five clauses and one more: "Plea Agreement Binding for Purposes of Removal Proceedings" (requiring Appellant to acknowledge that his waiver of immigration-related rights is binding in any future removal proceedings). Compare id. at 108-110 (draft plea agreement), with Supp. J.A. Vol. I at 1-13 (final plea agreement).

However, although it did not include an explicit waiver of rights related to removal from the United States, the final plea agreement did mention potential immigration consequences.

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Cite This Page — Counsel Stack

Bluebook (online)
927 F.3d 808, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-sergio-murillo-ca4-2019.