United States v. Martinez-Cruz, No. 12-3050 (D.C. Cir. 2013)
Annotate this CaseDefendant pleaded guilty to a single count of conspiracy to distribute methamphetamine. Defendant did not qualify for safety valve relief under 18 U.S.C. 3553(f) because his criminal history score under the Sentencing Guidelines was more than one point. Because of a prior driving-under-the-influence conviction in Georgia, for which he was on probation at the time of his arrest, his criminal history score was three points. Therefore, the district court found defendant ineligible for a sentence reduction. Defendant argued that at the time of his plea to the DUI charge he was not properly informed of his right to counsel and did not validly waive that right, so that the DUI charge was in violation of the Constitution. The court held that the government had the burden of persuasion, but only once the defendant produced objective evidence sufficient to support a reasonable inference that his right to counsel was not validly waived. Accordingly, the court remanded so that the district court could reexamine the evidence introduced by defendant. If defendant has produced objective evidence sufficient to support a reasonable inference that he did not validly waive the right to counsel, then the government must, by a preponderance of the evidence, persuade the court that the waiver was in fact valid.
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