United States v. Martin Miguel Lugo
1:24-cv-22321
| S.D. Fla. | Jun 30, 2025Background
- Miguel Martin Lugo operated a trucking business and was convicted after a jury trial for conspiracy to distribute cocaine and conspiracy to commit money laundering.
- Four co-defendants pled guilty and testified against Lugo; he was found not guilty of possession with intent to distribute cocaine.
- Lugo was sentenced to 292 months’ imprisonment and 5 years' supervised release; his sentence was affirmed by the Eleventh Circuit.
- Lugo filed a timely motion under 28 U.S.C. § 2255, alleging ineffective assistance of trial counsel on several grounds.
- The Motion was referred to a Magistrate Judge, who recommended denial; Lugo objected to nearly all findings, but the District Court conducted a de novo review and adopted the Magistrate's recommendations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance: Case agent's testimony | Counsel failed to object to improper case agent opinions and identification as "Tio." | Issues are either meritless or not prejudicial; testimony was permissible lay opinion. | Not ineffective; agent gave proper lay opinions. |
| Ineffective assistance: Prosecutor's closing | Counsel failed to object to vouching for witnesses and inflammatory statements about accountability. | Prosecutor's comments not improper, no vouching or inflammatory language. | Objection not warranted; arguments proper. |
| Ineffective assistance: Cross-examination | Counsel failed to fully expose co-defendants' incentives and benefits for testifying; no expert called. | Counsel reasonably explored bias and benefits; no requirement for expert. | Not ineffective; bias and benefits sufficiently presented. |
| Cumulative error | Counsel's errors collectively deprived Lugo of fair trial. | Without individual merit, no cumulative error possible. | No cumulative error; no basis for relief. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes standard for ineffective assistance of counsel claims)
- United States v. Hawkins, 934 F.3d 1251 (11th Cir. 2019) (addresses improper agent testimony at trial)
- United States v. Pendergrass, 995 F.3d 858 (11th Cir. 2021) (distinguishes permissible agent lay opinions from Hawkins)
- United States v. Sosa, 777 F.3d 1279 (11th Cir. 2015) (prosecutorial comments must be assessed in context)
- Chandler v. United States, 218 F.3d 1305 (11th Cir. 2000) (deference to trial counsel's decisions in ineffective assistance review)