Charles Watson, Jr. v. United States, 682 F.3d 740

Watson pled guilty to a drug conspiracy; death resulted from the distribution, yielding a 240-month statutory minimum,
Watson's plea waived direct appeal and collateral attack rights, including §2255 IAC claims,
Watson was sentenced to 165 months after a substantial‑assistance departure, counts dismissed,
Watson filed a §2255 motion within a year asserting four grounds including IAC and sentencing flaws, proscribed by the waiver,
The district court enforced the collateral attack waiver and denied relief; on appeal the court limited review to the IAC issue related to the plea, and affirmed the district court

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the collateral attack waiver bars Watson’s IAC claim about the plea	DeRoo requires relief when IAC relates to plea/waiver negotiation	Waiver bars all collateral challenges, including IAC	Waiver enforced; IAC claim barred as to plea-related issues
Whether Watson can show prejudice for IAC in the plea context	IAC prejudices Watson because it affected sentencing exposure	No prejudice; evidence shows alterable factors did not hinge on counsel’s advice	No prejudice established; district court did not err in denying relief without an evidentiary hearing

DeRoo v. United States, 223 F.3d 919 (8th Cir. 2000) (IAC claims tied to plea negotiations may survive waiver)
Chesney v. United States, 367 F.3d 1055 (8th Cir. 2004) (refinement of DeRoo's approach to waivers and IAC)
Hill v. Lockhart, 474 U.S. 52 (1985) (Strickland standard in guilty-plea context (prejudice))
Castellanos v. United States, 608 F.3d 1010 (8th Cir. 2010) (waiver is prudential, not jurisdictional; can review merits)
Lovelace v. United States, 565 F.3d 1080 (8th Cir. 2009) (plea waiver and collateral attack issues in appellate review)
Andis v. United States, 333 F.3d 891 (8th Cir. 2003) (discussion of waiver and potential conflict-related IAC considerations)