Warren v. United States

2011 DNH 030
CourtDistrict Court, D. New Hampshire
DecidedFebruary 16, 2011
Docket10-CV-527-SM
StatusPublished

This text of 2011 DNH 030 (Warren v. United States) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Warren v. United States, 2011 DNH 030 (D.N.H. 2011).

Opinion

Warren v . United States 10-CV-527-SM 2/16/11 UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Roy Warren, Petitioner

v. Case N o . 10-cv-527-SM Opinion N o . 2011 DNH 030 United States of America, Government

O R D E R

Petitioner was convicted, upon his guilty pleas, of robbery

and conspiracy to commit robbery, in violation of 18 U.S.C.

§ 1951. He was sentenced to 168 months in prison, which

represented a variant sentence above the range recommended by the

United States Sentencing Guidelines (“U.S.S.G.”). The conviction

and sentence were summarily affirmed on appeal. The court of

appeals held the variant sentence to be both procedurally sound

and substantively reasonable. United States v . Warren, N o . 09-

2063 (1st Cir. April 2 3 , 2010).

Petitioner now seeks relief under the provisions of 28

U.S.C. § 2255 on a number of grounds, including a claim of

ineffective assistance of counsel. First, petitioner raises

issues related to the advisory guideline calculation at

sentencing. They are without merit. The adjustment for theft of

controlled substances was correct — David Roy’s prescription medications (including narcotics) were stolen. David Roy was a

victim of the conspiracy. The adjustment based upon a vulnerable

victim (David Roy) was also correct. Again, David Roy was a

victim of the conspiracy and he was vulnerable.

Petitioner also says that the indictment only charged a

conspiracy to rob, and robbery o f , Justin (not David) Roy, so

David Roy should not have played any role in the sentencing

analysis. He is incorrect. Part of the conspiratorial activity

included robbing David Roy, and that act fell within the

guideline provisions governing relevant conduct. U.S.S.G. §

1B1.3 (sentencing adjustments are based upon all acts committed

by defendant and those acting in concert in committing the

offense of conviction). And, of course, alleged errors in

applying the guidelines to the facts of a case are generally not

cognizable under § 2255. See Knight v . United States, 37 F.3d

769 (1st Cir. 1994).

Next, petitioner claims that there was no interstate

commerce connection sufficient to support a Hobbs Act conspiracy

or robbery conviction. That is incorrect as well. At the plea

hearing the prosecutor proffered that Justin Roy was an unlawful

dealer in prescription drugs, that the drugs he sold were

manufactured outside the State of New Hampshire (so traveled in

2 interstate commerce), and that the money taken from Roy

represented proceeds from his illegal drug sales. By taking

those proceeds, petitioner and his co-conspirators effected a

depletion of Roy’s assets that could (and likely would) have been

used to support his illegal prescription drug dealing business.

All of which provides an adequate interstate commerce connection

— a connection petitioner acknowledged as part of his plea

colloquy. See United States v . DeCologero, 530 F.3d 36 (1st Cir.

2008).

Finally, petitioner says his counsel provided ineffective

assistance by failing to argue at sentencing that the government

breached the plea agreement when it declined to move the court to

award an additional one point reduction for acceptance of

responsibility. See United States v . Warren, N o . 08-cr-56-SM,

Plea Agreement (document n o . 3 7 ) , at para. 5 . Initially, the

probation officer recommended that petitioner be denied any

acceptance credit, based upon a state conviction that occurred

after his pleas in this case. At the sentencing hearing,

however, the court sustained petitioner’s objection to the

proposed denial of acceptance credit. The court determined that

the offense conduct underlying the state conviction took place

before the plea agreement in this case was executed, so

3 petitioner was entitled to a downward adjustment of two levels

for acceptance of responsibility.

Petitioner’s plea agreement also provided that if the

defendant assisted the United States in the investigation or

prosecution of his own misconduct by timely notifying the

government of his intention to plead guilty, the government would

move to decrease the base offense level by an additional one

level pursuant to U.S.S.G. § 3E1.1(b). At sentencing, however,

the government had misgivings (as did the probation officer)

about petitioner’s entitlement to any acceptance credit under the

guidelines, or under the plea agreement, given the issue related

to his contemporaneous criminal conduct. The plea agreement, by

its terms, relieves the government of any obligation to “not

oppose” acceptance credit if the defendant “after signing the

Plea Agreement, engages in additional criminal conduct.” Plea

Agreement, Para. 5 I . Whether petitioner’s post-plea state

conviction operated to deprive him of all acceptance credit was

an unresolved issue at sentencing.

Petitioner’s point here is that, as the court determined, he

did not engage in criminal conduct after the plea agreement was

signed and the government was, therefore, obligated to move for

an additional one point downward adjustment, since he did provide

4 timely notice of his intent to plead guilty. He adds that his

counsel’s failure to raise the issue at sentencing amounted to

constitutionally deficient representation.

While it appears that an additional one point reduction for

acceptance of responsibility probably should have been awarded,

the short answer to petitioner’s current ineffective assistance

claim is that it would have made no difference in the sentence

imposed. Before relief can be obtained on an ineffective

assistance of counsel claim, two things must be shown. First,

counsel’s performance must be shown to have fallen below an

objective standard of reasonableness. Strickland v . Washington,

466 U.S. 668 (1984). Second, defendant must show “a reasonable

probability that, but for counsel’s unprofessional errors, the

result of the proceeding would have been different.” Id. at 694.

Here, I doubt, under the circumstances, that counsel’s

performance fell below an objective standard of reasonableness

with respect to sentencing. But, even assuming for argument’s

sake that it did with respect to acceptance credit, still,

petitioner suffered no prejudice. As this court noted in

describing the reasons for imposing a variant sentence above the

recommended guideline range:

5 [Petitioner is] a committed antisocial violent person. His recidivism in the future is virtually assured. His use of violence in the future is virtually assured and the overarching consideration for me is this is clearly a case in which the public needs to be protected, and that factor far outweighs the mitigating factors that, Mr. Iacopino, you’ve articulated and referred to in your sentencing memorandum and in oral presentation. So I think a substantial sentence is warranted.

It’s coincidental because the probation officer’s recommendation [has] been rejected in many ways with respect to the assignment of enhancements, but his ultimate recommendation was 168 months, and I think that’s about right in this case.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Knight v. United States
37 F.3d 769 (First Circuit, 1994)
United States v. DeCologero
530 F.3d 36 (First Circuit, 2008)

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2011 DNH 030, Counsel Stack Legal Research, https://law.counselstack.com/opinion/warren-v-united-states-nhd-2011.