Case 3:12-cr-00164-JBA Document 280 Filed 12/29/14 Page 1 of 17

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA

Criminal No. 3:12cr164 (JBA)

v.
HECTOR MORALES

December 29, 2014

UNITED STATES SENTENCING MEMORANDUM

Rather than help his son pursue an education, obtain and maintain a job, or imbue him
with values that might allow him to contribute positively to society, Mr. Morales actively
participated in his sons drug dealing. Mr. Morales watched his son deal drugs from the family
porch, drive him to deals and money pickups, held his proceeds, and cautioned him that its
hot when he suspected police might be watching. When his son torched his neighbors building
in the middle of the night as part of a horribly warped attempt to collect a debt, Mr. Morales was
there to drive him from the scene. And in the aftermath of that gruesome crime, Mr. Morales
obstructed justice by altering the appearance of the get-away vehicle and coaching -- and when
necessary, intimidating -- witnesses who had been subpoenaed to testify before the grand jury
investigating the deaths of three innocents. Against this backdrop, the Court should impose a
term of incarceration within the advisory guidelines range of 168 to 210 months (14 to 17
years) of imprisonment.
I.

Facts and Circumstances of Defendants Crimes

On March 9, 2011, Quayshawn, Jaquetta and Wanda Roberson died in their third floor
apartment trying to escape an arson set by Mr. Morales son, Hector Natal, a Fair Haven drug
dealer. The other fourteen people in the house, though lucky to have survived, continue to suffer
from the horror of the fire. Mr. Morales drove Natal from the scene of the arson. In the hours,

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days and weeks following the arson, both defendants tried to obstruct the governments
investigation into the crime. On April 18, 2013, following a three-week trial, the defendants were
convicted on all counts. Mr. Morales has been convicted of three sets of crimes: (1) drug dealing;
(2) being an accessory after the fact to an arson that killed three people and displaced fourteen
others; and (3) tampering with witnesses and destroying evidence. These offenses are considered
below.
A. The Defendant Conspired to Sell Drugs with His Son
Evidence in the form of a drug seizure, a controlled narcotics purchase, law enforcement
surveillance, Natals phone records, recorded statements by Natal, and the testimony of Gabriel
Vega, Jessica Feliciano, Margaret Batts and Fernando Suarez proved Natals and Morales
complicity in a drug trafficking conspiracy. The evidence at trial plainly established that Natal
was an active and unrelenting drug dealer, and that Natal enlisted Morales assistance to hold his
drug money and to transport him to drug deals in the family van.
Natal dealt drugs in an open and notorious manner. Natal essentially conceded his
involvement in the drug trafficking conspiracy at trial. Tr. at 63 (As far as Mr. Natal is
concerned, this is not a case about whether Hector [Natal] was involved in drug dealing. He was.
He already pled guilty in this court to dealing drugs during this time period.); Tr. at 3475 (As
Mr. Sheehan said in his opening remarks, we do not dispute that Hector Natal was a drug
dealer.); Natal Post-Verdict Memo at p. 1 [Doc. No. 250]. PSR at 16.
But Natal did not act alone. Mr. Morales conspired with his son to sell drugs. Margaret
Batts, the defendants neighbor, testified that she watched Natal sell drugs from his porch in
front of his mother and father. Tr. at 46973. Mr. Morales also admitted to the grand jury that he
knew his son sold drugs. Tr. at 269091. PSR at 17-18.

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Several of Natals associates testified that Mr. Morales not only had knowledge of
Natals drug dealing, but that he actively participated in the dealing by knowingly driving Natal
to and from drug transactions. Gabriel Vega testified that Mr. Morales drove him and Natal to a
drug transaction on Monroe Street, and had warned his son that it was hot in the streets. Tr. at
1812. Vega recalled Natal giving Mr. Morales either drugs or money when he returned to the
van. Tr. at 1813. Vega also recalled that Mr. Morales drove Natal to the corner of Howard and
Spring Streets on the night of March 8, 2011 -- just hours before the fatal fire was set -- to collect
a $40 drug payment from Vega. Tr. at 181517. Similarly, Jessica Feliciano -- Natals
then-girlfriend -- testified that she was with Mr. Morales when he drove his son to a drug
transaction. Tr. at 230208. Feliciano, echoing Vegas testimony, also testified that Mr. Morales
warned his son that it was too hot and that the cops were watching the area. Tr. at 233234.
Feliciano also testified that Mr. Morales was present when Natal repackaged drugs for sale. Tr. at
2304. Finally, Feliciano testified that Natal trusted Mr. Morales to hold his drug proceeds. Tr. at
230708. PSR at 19-20.
B. The Defendant Drove His Son from the Arson
Mr. Morales conduct in the hour before the arson, as well as in the aftermath patently
demonstrates his complicity. Shortly before midnight, Mr. Morales picked up Natal at
Felicianos apartment and drove him in the family van to the intersection of Howard and Spring
Street so Natal could collect drug money from Vega. Not long afterwards, Morales van was at
the corner of Poplar Street and Wolcott Street, where Ms. Batts saw the defendants, who were
wearing masks and gloves, enter the van and drive from the corner. 1 Tr. at 508-511 and 515-16.
PSR at 28-29.
1 The government did not charge Mr. Morales with the arson because Natal told Vega he acted alone.

This conservative charging decision does not mitigate the fact that the defendant was wearing a mask and
at the corner with his son shortly before the buildings occupants began frantically calling 911.

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Phone records show that at approximately 1:36 a.m., Mr. Morales called Natal. Feliciano
testified that the conversation upset Natal. Tr. at 2325-26. Perhaps Mr. Morales was disturbed by
the incredible damage that the fire his son had set was causing. While it is not known what the
defendants specifically discussed, it is known that Mr. Morales gave conflicting and unbelievable
explanations to law enforcement about why he called Natal and what they discussed. First, on
May 6, 2011, Mr. Morales told FBI Special Agent Saul Cosme that on the night of the fire he
parked his van in front of his building, ate a Puerto Rican dish called sancocho and retired to bed
to watch an animal program on television. Tr. at 1406. Mr. Morales claimed that when he learned
of the fire, at 1:30 a.m., he immediately called Natal for two reasons: (1) he expected that the
residents would blame Natal for setting the fire (which at that point was still raging and had not
been ruled an arson) and, incongruously, (2) he was worried that Natal might be in the burning
building and wanted to confirm his safety. Tr. at 1409-13. PSR at 30.
With respect to Mr. Morales concern that Natal would be blamed for setting the fire, the
defendant stated that the residents of the burning building had previously blamed Natal for trying
to light a fire inside the building when in fact the culprit had been a Mexican jewelry salesman.
Tr. at 1409-11. PSR at 31.
Mr. Morales alternative explanation for calling his son his purported concern that
Natal might have been trapped in the burning building -- is equally implausible. Agent Cosme
testified:
A. The second reason, he just wanted to make sure his son wasnt inside 48-50 Wolcott
while the fire was going on.
Q. He had just told you his son had only been there once before, right?
A. Correct.
...

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Q. Did you follow up with Mr. Morales when he told you he wanted to make sure his son
was safe about the fact that
A. Yes.
Q. And what did he tell you?
A. We asked him if he had any friends or acquaintances or any type of relationship with
anyone from that residence, and he said no. So, we asked him why would he think that
his son was going to be inside that residence, and he said that he was just double
checking on his sons safety.
Q. Did he say whether he called anyone else to check on their safety -A. No.
Q. -- or to confirm that they werent in the building?
A. No.
Q. It was just his son he called.
....
Q. So, you said he was double checking on his sons safety, and I asked did he call on
anyone else to check on their safety?
A. He did not call on anyone else to check on their safety.
Tr. at 1411-13. PSR at 32.
On May 18, 2011, Mr. Morales testified before the grand jury investigating the arson and
provided a third, even more preposterous, explanation for why he called Natal during the fire:
Q. Sir, before you put on your clothes and go downstairs and the firefighters have now
arrived, didnt you immediately call your son after you spoke to your daughter?
A. Yes, I called him.
Q. Didnt you call him because you had reason to believe he was involved in setting that
fire?
A. No, it was because I heard somebody saying his name.
....
Q. The building is on fire. Have the firemen arrived?
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A. The firemen came when I was coming down.

Q. The firemen arrived. Are there a number of people outside?
A. Yes.
Q. And people are crying and yelling?
A. Yes.
Q. And amidst all of this commotion, you hear someone across the street say your sons
name Boom-Boom?
A. No, not from the other side, from the corner. Some woman saying Boom-Boom. I
dont know. The corner where I live.
Q. So now you are saying that this person was on the same side of the street where you
live?
A. Yes, the same corner. A woman on the very corner where my daughter lives. I dont
know where she lives, but I heard my sons name.
Q. How far away was she from where you were?
A. Im just saying I heard a voice, a womans voice. Im not saying I saw her. I heard her
mention my sons name, Boom-Boom, and so I immediately called him.
Q. What was she saying about your son Boom-Boom?
A. I dont know, I just heard his name.
Q. Where is this voice coming from?
A. From the corner where my daughter lives. But because there were a lot of people
there, I dont know who, you know. I dont know whose voice it was.
Q. Did you think the person who was saying your sons name was accusing your son of
being responsible or involved in this fire?
A. Yes, thats why I called him.
Q. Was this voice saying Boom-Boom set the fire, Boom-Boom is responsible?
A. No, I just heard his name, thats it.

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Tr. at 2692-94. A few weeks later, on June 1, 2011, Mr. Morales repeated his account of the
phantom voice to the FBI: [Morales] told me that on the night of the arson fire he had called his
-- he had actually heard a voice. He said a female voice screamed out the word Boom, . . . . He
told me it is his sons nickname, and that propelled him to want to call his son. And at that point
he says he called his son to see where he was, he was worried about him. Tr. at 809. When the
agent questioned Mr. Morales account, the defendant eventually . . . said that, in fact, he had
been lying, that that was not true, and he took that back. While the defendant signed a sworn
statement to that effect (Tr. at 811; Ex. 413), he has never provided a cogent answer to this
fundamental and telling question of why did he call his son as the fire raged. PSR at 33-34.
Mr. Morales was not at home on the night of the arson, as he claimed to the FBI and the
grand jury. First, Feliciano testified that Natal had been at her apartment the night of the fire, but
that he left around 11:45 p.m., after having placed a call to his father. Tr. at 2323-24. Next, Vega
testified that he saw both Mr. Morales and Natal on Spring Street approximately an hour before
fire -- they were there to collect a $40 drug debt from Vega. Tr. at 1815-17. And Feliciano
testified that Natal returned to her home alone at around 1:30 a.m., when she was awoken by an
angry phone conversation between Natal and his father about the fire. Tr. 2325-26. PSR at 35.
Mr. Morales, moreover, confessed to Feliciano that he drove Natal from the crime scene:
Q. You described [Morales] as being hysterical.
A. Yes. I got in the car and he was being hysterical, crying. I said, What happened? He
said, They about to give the death penalty to my son.
Q. That would be your boyfriend Hector Natal?
A. Yes.
Q. Okay, what was your reaction? What did you say?
A. I did not understand about giving the death penalty at the time, and so Morales had
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said, You just dont understand, I had drove him. So that kind of like leave me off
guard.
Q. All right, lets break that down and unpack it. He said, I drove him?
A. Yes.
Q. What does that mean?
A. He drove him from the fire to my house.
Tr. at 2363. PSR at 36.
Felicianos testimony was corroborated by Ms. Batts, who testified that she saw Mr.
Morales and his van at the scene and then driving from the area around the time the fire was set:
Q. Id like to start with a question about what you saw on March 9th, at about one oclock
in the morning on March 9, 2011. When you got back from the hospital that morning,
what did you see?
A. I seen, as I got out of the cab, I was walking towards my porch, and I noticed there
was Hector Morales van parked on the corner with -- running. It was running because -you could tell that because of the smoke that was coming out of the tailpipe.
....
Q. In addition to the van, what else did you see?
A. I seen two mens come around the corner dressed in all black proceeding towards the
van, Morales van.
Q. What happened after that?
A. As I was standing there, by then I was standing on my porch, and I happened to look. I
was looking at them the whole time, and I noticed that they turned around, the driver
turned around and looked at me.
....
Q. Would you explain to the jury how you were able to see the men who got into the van.
A. I was able to see by the height, the shape and the build, and from the top of the
foreheads that it, to me, appeared to be the Moraleses.
Tr. at 757-58. PSR at 37.

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C. The Defendant Sought to Obstruct Justice by Tampering with Witnesses and

Altering Evidence
In the wake of the three deaths, the defendants worked to manipulate witnesses into
falsely testifying before the grand jury. Feliciano testified that Morales and Natal gathered their
family together to discuss three falsehoods that should be included in everyones grand jury
testimony:

Jorge Natal (Natals uncle, Morales brother-in-law) was going to purchase Morales van;
a Mexican jewelry seller had attempted to set the first fire at 48-50 Wolcott Street; and
Natal had been home with Feliciano the entire night.

Tr. 236668. PSR at 38.

Feliciano testified that Mr. Morales instructed everyone to state that he had painted his
van from blue to black because Jorge Natal intended to purchase it from him:
Q: What did Hector Natal or Hector Morales say about the van?
A: It was more Hector Morales. He would sit there and tell us how Jorge Natal was
buying the van, he was going to buy the van with income tax money, he is painting the
van because he is going to buy it.
....
Q: Did you understand why you were being told that?
A: Yes.
Q: And what was your understanding?
A: My understanding were [sic] for everybody to get on the same page as he was going to
buy the van and the purpose why he painted it.
Tr. at 2369. PSR at 39.
Feliciano further testified that Jorge Natal did not want to buy the van and in fact did
not even have a drivers license -- and that Mr. Morales threatened to kick him out of the house if
he did not stick by the story. Tr. at 2370. When Jorge Natal continued to resist the pressure to
testify about the van, he had to give the defendant a computer in order to stay in the familys
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residence. Tr. at 2375-76. PSR at 40.

Feliciano also testified that in order to draw suspicion away from Natal, the defendants
instructed her to testify that a Mexican jewelry salesman had tried to start the first fire at 48-50
Wolcott Street:
Q: And what was the testimony that folks wanted to have about the Mexican?
....
A: All right. That the Mexican was coming by selling jewelry, he went into the building
that got on fire, and he tried to -- well, he went in there, try -- tried to sell them and
somebody had tried to rob him for the jewelry, and he came back a couple of days later
and tried to light the rugs on the hallway on fire.
Q: So, what did you understand you were to -- how you should testify at the grand jury
about the attempted arson earlier before the March arson?
A: What I had understand was try to put everything focusing on the Mexican, he already
tried to do it once, he going to do it again.
Q: And who was telling you to do that?
A: Morales.
....
Q: Did Hector Natal say anything about the Mexican in these meetings?
A: Yes.
Q: What was that?
A: The only thing he would always say you remember the Mexican was selling jewelry
and they tried to rob him.
Tr. at 237779. PSR at 41.
Finally, Feliciano testified that Natal pressured her to provide a false alibi for him for the
night of the fatal arson:
Q: And the third I think you told us was telling the grand jury where Hector Natal was on
the night of the fire.
A: Correct.

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Q: What were you being told? Who was telling you and what were you being told to say?
A: Natal would always say, Remember I was home with you all night. Like I felt a big
pressure with him. He would always tell me he was home all night, Remember I was
home all night with you.
....
Q: But you knew different?
A: Yes.
Tr. at 2380. PSR at 42.
Mr. Morales spray-painted his van from blue to black in an attempt to evade detection for
the arson. First, the jury had photographs of the van both before and after it had been primed
black. See Exs. 24A, 24B. Second, Mr. Morales grand jury testimony, in which he admitted to
painting the van after the fire, was admitted into evidence. This testimony included his
concession that although Jorge Natal wanted the van painted a different color, he did not have a
license and never paid Mr. Morales or completed paperwork for the sale. Tr. at 2681-83. And as
noted, Feliciano testified that the defendant instructed her and other members of the family to
falsify a story that the van had been painted to prepare it for sale to Jorge Natal. PSR at 43.
II.

Guidelines Calculations

The Probation Officer has correctly determined that the defendants offense level is 35,
which yields an advisory sentencing range of 168 to 210 months of imprisonment, a fine range of
$20,000 to $1,000,000, a term of supervised release of at least three years, and a special
assessment of $700. PSR at 45-73, 110-119. 2

2 The defendant did not provide the basis for his objections to the PSR to the government. The

government will review the defendants argument, as set out in his sentencing memorandum, and file a
timely response if necessary.

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Restitution is applicable in this case. The government is still attempting to obtaining

documentation of funeral expenses and related costs incurred by the victims of the arson. The
government will file a supplemental sentencing memo once those records have been obtained.
III.

Reasonable Sentence Under 18 U.S.C. 3553

A.

Legal Standard

Under 18 U.S.C. ' 3553(a), the sentencing court shall impose a sentence sufficient, but
not greater than necessary, to comply with the purposes set forth in paragraph (2) of this
subsection. Accordingly, sentencing courts must consider:
(1)

the nature and circumstances of the offense and the history and
characteristics of the defendant;

(2)

the need for the sentence imposed

(A) to reflect the seriousness of the offense, to promote respect for the law,
and to provide just punishment for the offense;
(B) to afford adequate deterrence to criminal conduct;
(C) to protect the public from further crimes of the defendant; and
(D) to provide the defendant with needed educational or vocational
training, medical care, or other correctional treatment in the most
effective manner;

(3)

the kinds of sentences available;

(4)

the kinds of sentence and the sentencing range established [in the
Sentencing Guidelines];

(5)

any pertinent policy statement [issued by the Sentencing

Commission];

(6)

the need to avoid unwarranted sentence disparities among defendants

with similar records who have been found guilty of similar conduct;
and

(7)

the need to provide restitution to any victims of the offense.

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See 18 U.S.C. 3553(a). These considerations strongly militate in favor of a lengthy term of
incarceration.
B. Analysis of Sentencing Factors

Nature and Circumstances of Offenses

Drug dealing, helping an arsonist escape a triple homicide, and tampering with witnesses

are three highly troubling offenses in their own right. Combining these crimes into one case
renders the nature of the offense abhorrent.
The circumstances surrounding Mr. Morales actions magnify the troubling aspect of
these crimes. The defendant conspired to deal drugs with his son. The defendant sought to help
his son get away with murder and did nothing to right the score. In fact, Mr. Morales worked to
get the story straight and conceal evidence of his own involvement in the crime.
Fathers should not corrupt or contribute to the corruption of their children. The nature
and circumstances of the crimes at hand are extremely troubling.

History and Characteristics of Defendant

The defendant does not have a criminal history. Accordingly, he is entitled to the benefit

of the lowest Criminal History Category. PSR at 74-77.

His employment history is virtually nonexistent. PSR at 90, 102-104. His primary
means of income has been his monthly Social Security Disability check. PSR at 102. Mr.
Morales cannot read or write, having dropped out of high school. PSR at 100-101. His family
has generally said nice things about him. PSR at 87, 89, 90.
At bottom, the defendants nature and history do nothing to change the sentencing
equation; these factors do not militate in favor of either leniency or a harsher penalty.

Seriousness of the Offense, Respect for the Law, and Providing Just Punishment

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These factors clearly warrant a significant sentence. Drug dealing is a serious offense.
Drug dealing with ones son is even more serious. It is one thing for a parent to be cursed with
not being able to positively guide a young person throughout life, helping him to make the right
choices. It is inexcusable for a parent to actively partake in his childs criminality.
The seriousness of being an accessory after the fact to a crime depends largely on the
seriousness of the underlying offense. Arson resulting in three deaths is as egregious a crime as
is imaginable. Simply put, as Wanda Roberson ran upstairs to find Quayshawn and Jaquetta, and
as Jaquetta covered Quayshawn with her own body to protect him from the flames, Mr. Morales
was driving the arsonist to safety.
Tampering with witnesses and altering evidence are crimes committed only if the
offender lacks respect for the judicial system. Unlike crimes committed in the heat of passion, or
offenses motivated by jealousy, greed, or poverty, an attempt to obstruct justice is driven by the
perpetrators belief that he is above the law. The seriousness of the offense is magnified when
the offender tries to influence the testimony of others because in these instances the offender
spreads the web of corruption beyond confederates -- who by definition have already been
corrupted -- to mere witnesses.
Wanda, Jaquetta and Quayshawn Roberson suffered horrible deaths. Their family and
friends continue to grapple with the pain and bewilderment of such senseless loss. The Foster
family similarly continues to suffer from the trauma of March 9, 2011. The Court will hear from
the surviving victims prior to imposing sentence. While the defendants convictions offer little
solace to the surviving victims, a just punishment surely contemplates a sentence within the
advisory guidelines range to reflect the seriousness of the defendants crimes and his lack of
respect for the law.

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Adequate Deterrence
Given that the defendant is 51 years old and facing a lengthy term of imprisonment under

even the best of circumstances, specific deterrence is not a consideration that ought to drive the
sentence in this case. But deterrence should not be used as basis for leniency, either. The
defendant, by actively seeking to tamper with witnesses, evinced a clear disrespect for the law.
While it can be debated whether imposing a significantly harsh sentence here will deter the
defendant from committing future crimes, it is clear that a downward departure from the
controlling advisory range will reaffirm the defendants misconception that he is above the law
and, by extension, embolden him the next time criminal opportunity arises.

Protection of the Public from the Defendant

Protection of the public from further crimes of the defendant is an important factor in this

case. The defendants criminal conduct involved drug dealing, arson, and witness tampering.
These serious offenses were not aberrational, and were committed over an extended time frame.
Mr. Morales body of work demonstrates a genuine need to protect the community.

Educational and Vocational Training, and Medical Care and Treatment

Nothing in the defendants educational history, employment background, or family

situation suggests the need for a significant sentence modification. As such, this is not a factor
that should impact the sentence.

Pertinent Guidelines Policy Statements

None applicable.

Restitution

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Prior to sentencing, the government will present to the Court, among other expenses, the
funeral costs incurred by the Robersons to bury Quayshawn, Jaquetta and Wanda.
IV.

Conclusion
The government respectfully submits that the Court should impose a sentence within the

advisory guidelines range of 168 to 210 months of imprisonment. Mr. Morales dealt drugs with
his son. And when his son torched a building over a drug debt, Mr. Morales drove his son to
safety. Three people died in the fire and countless others have been irreparably scarred by the
horror of that night. If Mr. Morales had his way, as he tampered with witnesses and altered the
appearance of his van, justice in the form of convictions would never have occurred. Under these
circumstances, a sentence within the advisory range will constitute a fair, just and reasonable
punishment.
Respectfully submitted,
DEIRDRE M. DALY
UNITED STATES ATTORNEY
/s/ Michael J. Gustafson
MICHAEL J. GUSTAFSON
ASSISTANT UNITED STATES ATTORNEY
FEDERAL BAR NO. CT 01503
157 Church Street, 25th Floor
New Haven, CONNECTICUT 06510
Telephone: (203) 821-3700

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CERTIFICATE OF SERVICE
I hereby certify that on December 29, 2014, the foregoing Sentencing Memorandum was
filed electronically. Notice of this filing will be sent by e-mail to all parties by operation of the
Courts electronic filing system or by mail to anyone unable to accept electronic filing. Parties
may access this filing through the Courts system.
William H. Paetzold, Esq.
Moriarty, Paetzold & Sherwood
2230 Main Street
Glastonbury, CT 06033

Michael O. Sheehan, Esq.

Sheehan & Reeve
139 Orange Street Suite 301
New Haven, CT 06510

Paul Thomas, Esq.

Office of Federal Public Defender
265 Church St, Suite 702
New Haven, CT 06510-7005

/s/ Michael J. Gustafson

MICHAEL J. GUSTAFSON
ASSISTANT UNITED STATES ATTORNEY

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