Uriana-Uriana v. United States

CourtDistrict Court, M.D. Florida
DecidedMay 28, 2025
Docket8:24-cv-02497
StatusUnknown

This text of Uriana-Uriana v. United States (Uriana-Uriana v. United States) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Uriana-Uriana v. United States, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

GASPARITO URIANA-URIANA, Prisoner, v. Case No. 8:24-cv-2497−KKM−NHA Case No. 8:23-cr-195-KKM-NHA UNITED STATES OF AMERICA, Respondent. ____________________________________

ORDER Prisoner Gasparito Uriana-Uriana moves to vacate his 132-month sentence

for conspiracy to possess with intent to distribute cocaine and possession with intent to distribute cocaine while on board a vessel subject to the jurisdiction of the United

States. 28 U.S.C. § 2255. Uriana-Uriana claims that his sentence was improperly enhanced for possession of a dangerous weapon and that counsel rendered constitutionally ineffective assistance at sentencing. Because his claims lack

merit, his motion to vacate is denied. I. Background

A grand jury indicted Uriana-Uriana with one count of conspiring to possess with intent to distribute five kilograms or more of cocaine while on board a vessel

subject to the jurisdiction of the United States, in violation of 46 U.S.C. §§ 70503(a) and 70506(a) and (b) and 21 U.S.C. § 960(b)(1)(B)(ii); and one count of possessing

with intent to distribute five kilograms or more of cocaine while on board a vessel subject to the jurisdiction of the United States, in violation of 46 U.S.C. §§ 70503(a) and 70506(a), 18 U.S.C. § 2, and 21 U.S.C. § 960(b)(1)(B)(ii). (Crim. Doc. 1.)

Uriana-Uriana pleaded guilty as charged without a plea agreement. (Crim. Docs. 44, 46, 47, and 54.)

The presentence report calculated an advisory guidelines range of 210 to 262 months based on Uriana-Uriana’s total offense level of 37 and his criminal history

category of I. (Crim. Doc. 59 at ¶ 53.) Counsel objected both to a two-level enhancement for possession of a dangerous weapon and to Uriana-Uriana’s ineligibility for safety-valve relief and zero-point offender status. (Crim. Doc. 59 at

21–22; Crim. Doc. 71; Crim. Doc. 82 at 5, 7 and 9.) Counsel argued that Uriana- Uriana lacked knowledge of the firearm that law enforcement recovered from the

vessel. (Crim. Doc. 82 at 5–6.) The district court overruled counsel’s objections. ( . at 14, 31, and 36.) The

district court found that sufficient evidence established that Uriana-Uriana knew the firearm was on the vessel based on the uncontested facts that the vessel was small,

the firearm was discovered under a five-gallon bucket “covering the most valuable items on any go-fast vessel, mainly the cellphones and satellite phone that contained

the [vessel’s destination] coordinates[,]” and Uriana-Uriana admitted that he was provided the GPS system with preprogramed coordinates.1 ( . at 14–15.) Uriana- Uriana failed to show that a connection between the firearm and the offenses was

clearly improbable because the “go-fast vessel is extremely small, [and] the gun was found in the same bucket as the most important navigation tool on the boat, which

is the satellite phones.” ( . at 21–22 and 31.) And, it was reasonably foreseeable, the district court concluded, that the firearm would be used in connection with drug-

trafficking offenses considering the volume of cocaine. ( . at 31–32.) Citing Uriana- Uriana’s personal history and characteristics, the district court varied downward from

1 Additionally, counsel represented that Uriana-Uriana’s personal items were found near the five- gallon bucket, which further confirmed he possessed the firearm in connection with the drug- trafficking offenses. ( . at 18 and 31.) the advisory guidelines range and sentenced him to concurrent sentences of 132

months. (Crim. Doc. 76; Crim. Doc. 77 at 3.) Uriana-Uriana filed no appeal. He now moves to vacate his sentence and

claims that (1) his sentence was improperly enhanced for possession of a dangerous weapon and (2) counsel rendered ineffective assistance at sentencing by not objecting

to the enhancement. (Civ. Doc. 1.) The United States responds that Uriana-Uriana’s claims are meritless.2 (Civ. Doc. 3.) II. Legal Standards

Section 2255 allows a federal prisoner to “bring a collateral challenge by moving the sentencing court to vacate, set aside, or correct the sentence.”

, 767 F.3d 1210, 1215–16 (11th Cir. 2014). But “[o]nce the defendant’s chance to appeal has been waived or exhausted, [a court is] entitled to

presume he stands fairly and finally convicted, especially when . . . he already has had a fair opportunity to present his federal claims to a federal forum.”

2 The United States correctly argues that Uriana-Uriana procedurally defaulted his sentencing claim by neglecting to raise it on direct appeal. For judicial economy, the district court rejects Uriana-Uriana’s sentencing claim as meritless. , 964 F.3d 1285, 1307 (11th Cir. 2020) (“As we have said many times and as the Supreme Court has held, a federal court may skip over the procedural default analysis if a claim would fail on the merits in any event.”); , 73 F.4th 1354, 1359 n.9 (11th Cir. 2023) (same). , 456 U.S. 152, 164 (1982). “[A] collateral challenge, such as a § 2255

motion, may not be a surrogate for a direct appeal.” , 365 F.3d 1225, 1232 (11th Cir. 2004) ( ) (citing , 456 U.S. at 165). Because

collateral review is not a substitute for direct appeal, a defendant must raise on direct appeal all available claims. Relief under Section 2255 is reserved “for transgressions

of constitutional rights and for that narrow compass of other injury that could not have been raised in direct appeal and would, if condoned, result in a complete miscarriage of justice.’” , 837 F.2d 965, 966 (11th Cir.

1988) (quoting , 656 F.2d 1033, 1037 (5th Cir. Unit A Sep. 1981)). For example, a claim of ineffective assistance of counsel is a claim that

“should usually be raised in a motion under 28 U.S.C. § 2255.” , 726 F.3d 1260, 1267(11th Cir. 2013).

“[T]he cases in which habeas petitioners can properly prevail on the ground of ineffective assistance of counsel are few and far between.” , 46 F.3d 1506, 1511 (11th Cir. 1995) (en banc) (quoting , 13 F.3d

384, 386 (11th Cir. 1994)). As , 155 F.3d 1297, 1305 (11th Cir. 1998), explains, , 466 U.S. 668

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