Wassouf v. United States

2011 DNH 021
CourtDistrict Court, D. New Hampshire
DecidedFebruary 7, 2011
Docket11-CV-51-SM
StatusPublished

This text of 2011 DNH 021 (Wassouf 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
Wassouf v. United States, 2011 DNH 021 (D.N.H. 2011).

Opinion

Wassouf v . United States 11-CV-51-SM 2/7/11 UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

George Wassouf

v. Case N o . 11-cv-51-SM Opinion N o . 2011 DNH 021 United States of America

O R D E R

Almost ten years ago, the petitioner, a Syrian citizen, pled

guilty to and was convicted of bank fraud in this court. United

States v . Wassouf, N o . 01-cr-1-SM (D.N.H.). He was sentenced to

33 months in prison and a 5-year period of supervised release.

Petitioner completed his prison sentence on October 1 , 2003.

He was promptly taken into custody by Immigration and Customs

Enforcement agents, and deportation proceedings were begun, based

upon his federal conviction. Petitioner then filed a motion for

relief from his conviction and sentence under the provisions of

28 U.S.C. § 2255, claiming that his trial defense counsel

provided constitutionally deficient representation, in that he

failed to file a notice of appeal as petitioner had directed.

After considering the record, and trial counsel’s response, the

court granted the motion to the extent of affording petitioner a

renewed opportunity to file an appeal, which he did. See Wassouf

v . United States, 2003 WL 22474623 (D.N.H. Oct. 3 1 , 2003). Because petitioner took advantage of the opportunity to appeal,

his conviction was no longer final. Accordingly, the

administrative removal proceedings were terminated without

prejudice, pending final resolution of petitioner’s criminal

case.

On his belated direct appeal petitioner argued, inter alia,

that his trial counsel failed to tell him that his guilty plea to

a felony might result in his being deported. On that basis, he

sought to have his conviction overturned and his plea withdrawn.

In 2005, the court of appeals affirmed the conviction and

sentence, finding that petitioner abandoned his ineffective

assistance claim, because he raised it in only a perfunctory

manner, unaccompanied by any developed argument. The court also

noted that the claim appeared to be meritless. See United States

v . Wassouf, App. N o . 03-2602 (1st Cir. Sept. 1 3 , 2005). At that

time, no circuit court of appeals had held that defense counsel’s

failure to advise a non-citizen defendant that a guilty plea and

conviction might result in removal proceedings constituted

ineffective assistance of counsel under the Sixth Amendment.

Those courts that had considered the issue generally agreed that

such a failure related only to a collateral matter, and did not

deprive a criminal defendant of effective assistance of counsel

in the criminal prosecution.

2 Petitioner’s 5-year term of supervised release was scheduled

to expire on October 1 , 2008. Because he resided in

Massachusetts, on September 6, 2006, jurisdiction was transferred

to the District of Massachusetts. Petitioner had by then

violated the terms of his supervised release and, after pleading

guilty, was sentenced in December of 2006, to 6 months in prison

followed by 12 months of supervised release. United States v .

Wassouf, N o . 06-cr-10300-NMG, (D. Mass.). Petitioner completed

the 6-month sentence in June of 2007, after which he was again

promptly taken into custody pending removal, or deportation,

proceedings. (The 12-month supervised release term presumably

expired without further violations in June of 2008.)

The renewed deportation proceedings were also dismissed,

without prejudice, for procedural reasons. But, within a week of

that procedural dismissal, removal proceedings were begun yet

again. See Wassouf v . United States, et a l . , N o . 09-cv-11738-RWZ

(D. Mass.). On December 3 , 2007, an Administrative Law Judge

ordered petitioner removed to Syria, which order was subsequently

carried out.

On March 3 1 , 2010, the Supreme Court decided Padilla v .

Kentucky, 130 S.Ct. 1473 (2010), holding that criminal defense

counsel are obligated to inform their non-citizen clients of the

3 deportation consequences of a guilty plea and resulting

conviction. Id. at 1483. Failure to so advise a non-citizen

client will, in most cases, render counsel’s performance

constitutionally deficient, under the first part of the

ineffective assistance of counsel test set out in Strickland v .

Washington, 466 U.S. 668 (1984). Based on Padilla, petitioner

filed the pending motion seeking to collaterally attack his

federal bank fraud conviction, on ineffective assistance of

counsel grounds. The government objects.

Petitioner styles his motion as one for coram nobis relief

under the All Writs Act, 28 U.S.C. § 1651, rather than one for

relief under 28 U.S.C. § 2255. Neither petitioner nor the

government addresses his custody status at the time he filed the

motion (July 9, 2010), but the record discloses that petitioner

was no longer in custody with respect to the challenged

conviction.

By July of 2008, two years before this motion was filed,

petitioner had completed the 33-month sentence, the 6-month

sentence imposed for violations of the terms of his supervised

release, and the 12-month period of reimposed supervised release.

If petitioner had been “in custody” in July of 2010, then his

motion could not be considered by this court. In that

4 circumstance, § 2255 would provide the appropriate remedy, not

coram nobis, and the motion would be recast as a second or

successive petition under § 2255. The court of appeals has not

certified that the motion invokes a “new rule of constitutional

law, made retroactive to cases on collateral review by the

Supreme Court, that was previously unavailable,” so this court

would be without jurisdiction to consider that second or

successive petition. 28 U.S.C. § 2255(h)(2); see Trenkler v .

United States, 536 F.3d 8 5 , 98 (1st Cir. 2008).

The writ of coram nobis, on the other hand, “is ordinarily

available only to a criminal defendant who is no longer in

custody.” Id. As it seems reasonably certain that petitioner

was no longer “in custody” with respect to the challenged

conviction when he filed the motion, the relief provided by §

2255 is not available to him. But coram nobis relief i s . And,

as the petition represents a collateral challenge that is civil

in nature, it is properly docketed as a separate case.1

Whether petitioner can benefit from Padilla’s holding

depends, initially, upon whether it is retroactively applicable

to his case. Those courts that have considered whether Padilla’s

1 Petitioner filed the motion in the underlying criminal case. The Clerk has been directed to assign the petition a civil docket number.

5 rule has retroactive effect are decidedly not in agreement. See

e.g., United States v . Haddad, 2010 WL 2884645 (E.D. Mich. July

2 0 , 2010) (Padilla is not retroactively applicable); United

States v . Gilbert, 2010 WL 4134286 (D.N.J. October 1 9 , 2010)

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Related

Padilla v. Kentucky
559 U.S. 356 (Supreme Court, 2010)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hernandez v. Gonzales
424 F.3d 42 (First Circuit, 2005)
United States v. Chaidez
730 F. Supp. 2d 896 (N.D. Illinois, 2010)
Premo v. Moore
178 L. Ed. 2d 649 (Supreme Court, 2011)
United States v. Avilés-Colón
536 F.3d 1 (First Circuit, 2008)

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2011 DNH 021, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wassouf-v-united-states-nhd-2011.