United States v. Marin-Echeverri, No. 15-2187 (1st Cir. 2017)Annotate this Case
Defendant pleaded guilty to participating in a conspiracy to import one or more kilograms of heroin into the United States and to launder the proceeds of that activity. Defendant was sentenced to 262 months in prison. On appeal, Defendant argued that the government violated the plea agreement during the sentencing hearing and that his counsel provided constitutionally ineffective assistance during the plea negotiations and at the sentencing hearing. The First Circuit (1) affirmed the sentence, holding that there was no breach of the plea agreement; and (2) dismissed the ineffective assistance of counsel claim without prejudice to its reassertion in a collateral proceeding, as there was no reason to make an exception in this case to the rule that this Court does not review ineffective assistance of counsel claims on direct appeal.