Narrative Opinion Summary
In this case, the defendants, who initially pled guilty, attempted to withdraw their pleas, asserting they were misled by their prior attorneys regarding the possibility of plea withdrawal. Their motions were initially denied following hearings and recommendations by a magistrate judge. The defendants subsequently introduced affidavits alleging coercion by their counsel, leading to further evidentiary hearings. Testimonies from the defendants' former attorneys and a law clerk uniformly contradicted the defendants' claims, with the court finding the affidavits insufficient and lacking credibility, particularly as one defendant admitted to signing without reading or translation. The court denied the amended motion to withdraw the guilty pleas, citing a lack of evidence and consistency in the affidavits, and imposed a two-level enhancement for obstruction of justice due to the submission of false affidavits, which caused procedural delays. The court scheduled a new sentencing date, reaffirming the initial guilty pleas and addressing the obstruction of justice enhancement under the sentencing guidelines.
Legal Issues Addressed
Evidentiary Hearing and Affidavit Evaluationsubscribe to see similar legal issues
Application: The court conducted multiple evidentiary hearings to evaluate affidavits presented by the defendants, concluding that the affidavits lacked sufficient evidence to counter the testimonies of the defendants' former attorneys.
Reasoning: All three witnesses consistently denied the Defendants' allegations, indicating that the affidavits lacked sufficient evidence to challenge their testimonies, which were emphatically stated as false.
Obstruction of Justice Enhancementsubscribe to see similar legal issues
Application: Due to the submission of false affidavits and the resulting delays, the court applied a two-level increase in the defendants' sentencing for obstruction of justice under U.S.S.G. 3C1.1.
Reasoning: Consequently, the court finds no grounds for the defendants’ amended motion to withdraw guilty pleas and decides to impose a two-level increase for obstruction of justice on both Calderon and Patino-Cardona, referencing U.S.S.G. 3C1.1, Comment (n. 3(c).
Withdrawal of Guilty Pleasubscribe to see similar legal issues
Application: The defendants sought to withdraw their guilty pleas, claiming they had been misled by prior counsel about their ability to do so. The court found the claims to be conclusory and self-serving, ultimately denying the motions.
Reasoning: The Defendants later claimed their prior counsel had misled them regarding the ability to withdraw their pleas and proceed to trial. The court found these claims to be conclusory and self-serving, thereby denying their motion on October 10, 1991.