United States v. Victor Manzanillo

CourtCourt of Appeals for the Third Circuit
DecidedNovember 5, 2024
Docket23-2259
StatusUnpublished

This text of United States v. Victor Manzanillo (United States v. Victor Manzanillo) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third 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. Victor Manzanillo, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________

No. 23-2259 ____________

UNITED STATES OF AMERICA

v.

VICTOR MANZANILLO, Appellant ____________

On Appeal from the United States District Court for the District of New Jersey (D.C. Crim. No. 2:22-cr-00617-001) District Judge: Honorable Susan D. Wigenton ____________

Submitted Pursuant to Third Circuit LAR 34.1(a) October 28, 2024 ____________

Before: CHAGARES, Chief Judge, PORTER, and CHUNG, Circuit Judges.

(Filed: November 5, 2024) ____________

OPINION* ____________

* This disposition is not an opinion of the full Court and, pursuant to I.O.P. 5.7, does not constitute binding precedent. CHAGARES, Chief Judge.

Victor Manzanillo pled guilty to several Hobbs Act robberies and conspiracies,

wire fraud, and aggravated identity theft. He argues that his trial counsel was ineffective

for failing to inform him about the details of his plea agreement, file dispositive motions,

or provide him with discovery materials, as well as for not challenging an increase in his

offense level under the U.S. Sentencing Guidelines (“Guidelines”). For the reasons

below, we will affirm the judgment of the District Court.

I.

We write primarily for the parties and so recite only those facts pertinent to our

decision. In February and March 2020, Manzanillo and multiple co-conspirators robbed

four cellphone stores. In some of these robberies, they physically restrained and

threatened the stores’ employees. Manzanillo and another co-conspirator also stole store

customers’ personal information to create fake drivers’ licenses and fraudulently

purchase electronic devices.

Manzanillo signed a plea agreement with the Government and pled guilty to a ten-

count information. Counts 1–8 charged him with committing and conspiring to commit

Hobbs Act robbery, 18 U.S.C. § 1951(a); Count 9 charged him with wire fraud, id.

§ 1343; and Count 10 charged him with aggravated identity theft, id. § 1028A(a)(1).

Through counsel, he stipulated to a final offense level of 24 under the Guidelines, along

with a mandatory consecutive term of imprisonment of 24 months for the aggravated

identity theft charge. Though he waived his right to appeal his sentence in the plea

2 agreement, he did not give up the right to assert an ineffective assistance of counsel

claim.

The District Court sentenced Manzanillo to 96 months of imprisonment: the

mandatory 24-month term for the aggravated identity theft count and 72 months for the

other nine counts. This sentence was based on a final offense level of 24, the 24-month

mandatory minimum, and a Category III criminal history, for which the Guidelines

recommended 87 to 102 months of imprisonment. Manzanillo timely appealed.

II.1

Manzanillo asserts that his trial counsel was ineffective before and after his guilty

plea. He first argues that his trial counsel did not sufficiently inform him about the plea

agreement, move to dismiss the prosecution, or allow him access to discovery materials.

He then argues that his trial counsel should have challenged the plea agreement, which

allegedly miscalculated his offense level. His first argument is unsuitable for direct

appeal, and his second lacks merit.

A.

We first consider Manzanillo’s allegations of ineffective assistance prior to his

guilty plea. Manzanillo asserts that his lawyer lied to him about his criminal history

calculation, forcing him to accept a Category III criminal history rather than Category II.

1 The District Court had jurisdiction under 18 U.S.C. § 3231. We have jurisdiction to review Manzanillo’s conviction and sentence under 28 U.S.C. § 1291 and 18 U.S.C. § 3742(a). “We exercise plenary review over the District Court’s legal conclusions and apply a clearly erroneous standard to its factual findings.” United States v. Scripps, 961 F.3d 626, 631 (3d Cir. 2020). 3 He also claims that his attorney failed to move to dismiss the charges, properly review the

plea agreement with him, or heed Manzanillo’s desire to go to trial.

But this Court has consistently refused to consider ineffective assistance of

counsel claims on direct appeal. See United States v. Morena, 547 F.3d 191, 198 (3d Cir.

2008). “[S]uch claims frequently involve questions regarding conduct that occurred

outside the purview of the district court and therefore can be resolved only after a factual

development at an appropriate hearing.” Gov’t of Virgin Islands v. Zepp, 748 F.2d 125,

133 (3d Cir. 1984) (emphasis omitted) (quoting United States v. Swinehart, 617 F.2d 336,

340 (3d Cir. 1980)). Instead, a collateral proceeding is better suited to addressing such

claims. See United States v. McLaughlin, 386 F.3d 547, 555–56 (3d Cir. 2004).

Though we sometimes find an exception to this rule, this set of claims does not

qualify. When “the record is sufficient to allow determination of ineffective assistance of

counsel,” we may review such claims. United States v. Headley, 923 F.2d 1079, 1083

(3d Cir. 1991). Manzanillo alleges that his former counsel misrepresented details of the

plea agreement, failed to file dispositive motions, and precluded him from accessing

discovery materials. The record before us, however, is silent on each of those issues,

which are therefore unresolvable at this time. Manzanillo may instead raise these

challenges in a petition for collateral review under 28 U.S.C. § 2255.

B.

Manzanillo also argues that his former counsel should have challenged his

sentence, which he says was miscalculated. He asserts that the plea agreement should

have assigned him eight fewer levels for the offense level associated with the wire fraud

4 count. The plea agreement assessed a six-level increase based on an intended loss of

more than $40,000, but Manzanillo argues “loss is not intended loss, but actual loss” for

sentencing calculations. Manzanillo Br. 22 (citing United States v. Banks, 55 F.4th 246

(3d Cir. 2020)). And the agreement included a two-level increase because the scheme

involved ten or more victims, but Manzanillo asserts that only “one person suffered

actual loss.” Id. Therefore, while the plea agreement calculated the wire fraud offense

level as 15, Manzanillo asserts that it should have been only 7.

Because the record is clear on this matter, we may consider this ineffective

assistance claim. We review such claims under the framework outlined in Strickland v.

Washington, which requires a defendant to show both that counsel’s performance was

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Related

United States v. Franks
230 F.3d 811 (Fifth Circuit, 2000)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
United States v. Robert Dennis Swinehart
617 F.2d 336 (Third Circuit, 1980)
United States v. Marva Headley, A/K/A "Brenda"
923 F.2d 1079 (Third Circuit, 1991)
United States v. Steven McLaughlin
386 F.3d 547 (Third Circuit, 2004)
United States v. Brian Booth
432 F.3d 542 (Third Circuit, 2005)
United States v. Morena
547 F.3d 191 (Third Circuit, 2008)
United States v. Otero
502 F.3d 331 (Third Circuit, 2007)

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