United States v. Urias-Marrufo

Summary

The Fifth Circuit held that a district court must address a sufficiently presented claim under Padilla v. Kentucky when raised in a motion to withdraw a guilty plea before sentencing. The court vacated the denial of Ana Victoria Urias-Marrufo’s motion and remanded for factual findings on whether counsel failed to advise her of certain deportation consequences and whether that failure affected her plea.

Holdings

1. When a Padilla ineffective-assistance claim is sufficiently presented both legally and factually during a motion to withdraw a guilty plea, the district court errs by declining to address the claim on the ground that it belongs only in a collateral proceeding.
2. A plea colloquy informing a defendant that immigration consequences are possible does not cure counsel's alleged failure to advise the defendant of certain deportation consequences required by Padilla.
3. The record did not permit the appellate court to decide whether a Padilla violation occurred; therefore, the proper remedy was to vacate and remand for the district court to address the merits of the claim, without mandating a particular result.

Questions Presented

1. Whether the district court abused its discretion by denying Urias's presentence Rule 11 motion to withdraw her guilty plea.
2. Whether a sufficiently presented claim that counsel violated Padilla v. Kentucky by failing to advise a noncitizen of certain deportation consequences must be addressed in a Rule 11 motion to withdraw a guilty plea on direct appeal.
3. Whether the plea colloquy's acknowledgment of possible immigration consequences eliminated the need to address counsel's alleged failure to provide constitutionally required advice.

Disposition

vacated