United States v. Santiago Miranda
2011 U.S. App. LEXIS 17148
| 1st Cir. | 2011Background
- Santiago pled guilty to Count Five (conspiracy to possess with intent to distribute cocaine, crack, and marijuana) and waived appellate rights as part of the plea agreement.
- The district court found Santiago competent to plead and reviewed the change-of-plea colloquy, where Santiago testified he understood rights and waived options.
- Probation prepared a PSR showing CHC III and no requested departures; Santiago initially contested acceptance of responsibility, which affected the PSR.
- Santiago moved to withdraw his guilty plea on May 22, 2007, alleging involuntariness due to drug use, bipolar history, and family coercion; he provided a sworn statement later describing coercion.
- The district court ordered a competency evaluation; it later denied the motion to withdraw; sentencing was based on a total offense level of 43 and CHC III, resulting in a 380-month sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the motion to withdraw ple a should have been granted or an evidentiary hearing required | Santiago argues involuntariness due to drug use, sleep deprivation, and family coercion. | Miranda contends the court should have allowed withdrawal and held an evidentiary hearing. | The court did not abuse its discretion; no evidentiary hearing was required. |
| Whether the change-of-plea colloquy and plea agreement adequately contradict the withdrawal allegations | Sworn statement showed coercion and impairment undermining voluntariness. | Colloquy and plea agreement negate voluntariness; statements lack corroboration. | The district court was entitled to rely on the plea colloquy and agreement, denying withdrawal without a hearing. |
| Whether the timing and nature of the withdrawal motion undermine its legitimacy | Late, post-PSR revelation seeking leniency due to potential guidelines changes. | Motion timed after unfavorable PSR indicates recalculation rather than involuntariness. | Timing weighed against movant; not a fair and just reason to withdraw. |
Key Cases Cited
- United States v. Isom, 580 F.3d 43 (1st Cir. 2009) (frames test for withdrawal of guilty plea and relevant factors)
- United States v. Pulido, 566 F.3d 52 (1st Cir. 2009) (availability of an evidentiary hearing when facts alleged would entitle relief)
- Blackledge v. Allison, 431 U.S. 63 (1977) (declarations at plea proceedings carry strong presumption of verity)
- United States v. Torres-Rosario, 447 F.3d 61 (1st Cir. 2006) (plea colloquy representations receive weight absent reason to disregard)
- United States v. Doyle, 981 F.2d 591 (1st Cir. 1992) (post-hoc rationalization and sentence increase not fair basis to withdraw plea)
- United States v. Padilla-Galarza, 351 F.3d 594 (1st Cir. 2003) (corroboration required to support claims of impairment affecting voluntariness)