Law School Case Brief
United States v. Piedra-Morales - 843 F.3d 623 (5th Cir. 2016)
Permitting an attack on a prior conviction would undermine the finality of such convictions, requiring courts repeatedly to reconsider arcane issues regarding prior convictions.
Defendant Efrain Piedra-Morales was caught and pled guilty to illegal reentry into the United States. Previously, he had been deported three times from the United States. At his subsequent deportation hearing in federal district court, the court applied an eight-level aggravated felony enhancement for deportation after an earlier aggravated felony conviction, which he had pled guilty to. Piedra-Morales appealed, contending that his prior convictions for illegal reentry were not aggravated felonies because they were predicated on his prior cocaine possession convictions, which were no longer considered aggravated felonies under Lopez v. Gonzales, 549 U.S. 47, 50, 60, 127 S. Ct. 625, 166 L. Ed. 2d 462 (2006). Because the cocaine possession convictions were no longer aggravated felonies, he argued that his prior illegal reentry convictions are also not aggravated felonies.
Was the district court's sentence proper?
The federal appellate court affirmed the sentence imposed by the district court. The court held that because Piedra-Morales pled guilty twice under § 1326(b)(2), the district court did not err in applying an eight-level aggravated felony enhancement to the instant, third conviction. The court explained that the judgments for the prior illegal reentry convictions specifically indicated that Piedra-Morales pleaded guilty under § 1326(b)(2) based on an aggravated felony conviction. His guilty pleas expressly eliminated the interpretive question he raised regarding whether his prior illegal reentry convictions were not aggravated felonies. The court noted that permitting an attack on a prior conviction would undermine the finality of such convictions, requiring courts repeatedly to reconsider arcane issues regarding prior convictions.
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