Ronney Stuckey v. Michael L. Crews, 706 F. App'x 609

Stuckey was convicted after a jury trial of two counts of sexual battery involving a child and sentenced to life without parole (later corrected to life with parole eligibility after a 25-year mandatory minimum).
The State made plea offers (recorded as 15-year and 12-year offers; Stuckey later testified there had also been a 25-year offer). Stuckey rejected all offers and insisted on going to trial, maintaining his innocence.
Trial counsel Desmond sent a detailed letter about the 15-year offer, discussed the 12-year offer shortly before trial, and encouraged Stuckey to accept a plea given the strength of the State’s evidence.
At a Rule 3.850 hearing, Stuckey alleged counsel misadvised him about “gain time” (parole/credit calculations), telling him he would serve ~85% of a 12-year plea (~10.2 years) when under the applicable pre-1995 scheme he would have served closer to ~60% (~7.2 years).
The state 3.850 court found counsel’s precise gain-time advice was deficient (or equivocal) but credited contemporaneous documents and Desmond’s testimony that Stuckey was adamant about going to trial; it ruled Stuckey failed to show prejudice (would not have accepted the plea).
The First DCA summarily affirmed; Stuckey filed §2254. The district court denied relief but granted a COA limited to whether counsel’s misadvice about time-to-serve rendered assistance ineffective. The Eleventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel rendered ineffective assistance by failing to accurately advise Stuckey how much actual time he would serve under the 12‑year plea (gain-time misadvice)	Stuckey: had he known he would serve ~7.2 years (60%) rather than ~10.2 years (85%), he would have accepted the 12‑year plea; counsel failed to explain gain‑time, causing prejudice	State/Desmond: counsel discussed plea offers and warned of life exposure; contemporaneous records and testimony show Stuckey rejected multiple, increasingly favorable offers and insisted on trial, so no reasonable probability he would have accepted	Held: Court affirms — counsel may have been deficient about gain‑time detail, but state court reasonably found no prejudice; Stuckey likely would still have refused the plea
Whether Stuckey can expand COA to broader claim that counsel failed to prepare/advise about the case overall	Stuckey: broader misadvice context would show cumulative deficiency making plea rejection reasonable	State: COA limited to gain‑time claim; broader claim was not certified for appeal and was treated separately by state courts	Held: Court rejects expansion; only gain‑time claim within COA is considered

Stewart v. Secretary, Department of Corrections, 476 F.3d 1193 (11th Cir. 2007) (standard of review for §2254 appeals)
Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA deference: state-court merits determinations and "fairminded jurists" standard)
Schriro v. Landrigan, 550 U.S. 465 (2007) (§2254(d) objective unreasonableness standard)
Lafler v. Cooper, 566 U.S. 156 (2012) (prejudice standard for ineffective assistance in plea context)
Nejad v. Attorney General, 830 F.3d 1280 (11th Cir. 2016) (Strickland framework restated)
Bishop v. Warden, 726 F.3d 1243 (11th Cir. 2013) (both Strickland prongs required)
Consalvo v. Secretary, Department of Corrections, 664 F.3d 842 (11th Cir. 2011) (federal habeas courts defer to state-court credibility findings)
Osley v. United States, 751 F.3d 1214 (11th Cir. 2014) (post‑conviction pleading that rejection of prior offers and professed innocence undercuts claim that defendant would have accepted plea)