Roberto Barajas v. United States, 877 F.3d 378

Roberto Barajas, a Mexican national, pleaded guilty in 2009 to possessing a stolen firearm (18 U.S.C. § 922(j)); the conviction was an "aggravated felony" triggering deportation under federal immigration law.
Barajas was deported after serving his sentence and filed a § 2255 petition in 2010 claiming trial counsel was ineffective for failing to advise him of deportation risk.
The district court granted relief in 2012 relying on Padilla v. Kentucky (counsel must advise about immigration consequences). The Government appealed.
While appeal was pending, the Supreme Court decided Chaidez, holding Padilla announced a "new rule" under Teague and thus cannot be applied retroactively to cases on collateral review. The Eighth Circuit vacated the grant and remanded.
On remand the district court denied relief under Teague; Barajas appealed, arguing Teague should not bar retroactive application to federal § 2255 petitions or to ineffective-assistance claims.

Issue	Plaintiff's Argument (Barajas)	Defendant's Argument (Government)	Held
Does Teague's ban on retroactive application of "new rules" apply to collateral review of federal convictions under § 2255?	Teague was about state comity; federal context lacks those comity/federalism concerns so Teague should not apply.	Teague's finality rationale is independent of comity; federal convictions implicate finality too, so Teague applies.	Teague applies to collateral review of federal convictions; Eighth Circuit joins other circuits in so holding.
Should ineffective-assistance-of-counsel claims be exempt from Teague (i.e., allow Padilla retroactively on collateral review)?	Strickland already protects finality; ineffective-assistance claims are usually raised on collateral review so they should be treated differently.	Teague and Strickland serve different functions; Strickland is a limited procedural-default exception and does not obviate Teague's protection of finality across rule changes.	No exception; Teague bars retroactive application of Padilla to convictions final before Padilla, including ineffective-assistance claims on collateral review.

Teague v. Lane, 489 U.S. 288 (1989) (established that "new rules" of criminal procedure are not retroactive on collateral review to protect finality)
Padilla v. Kentucky, 559 U.S. 356 (2010) (held counsel must advise clients about immigration consequences of guilty pleas under Sixth Amendment)
Chaidez v. United States, 568 U.S. 342 (2013) (held Padilla announced a new rule under Teague and thus is not retroactive on collateral review)
Strickland v. Washington, 466 U.S. 668 (1984) (two-part test for ineffective assistance of counsel)
Massaro v. United States, 538 U.S. 500 (2003) (ineffective-assistance claims may be raised first on collateral review; procedural-default rationale)
United States v. Frady, 456 U.S. 152 (1982) (federal interest in finality of criminal judgments similar to states)