Sawyer v. United States
874 F.3d 276
7th Cir.2017Background
- Datqunn Sawyer was convicted in 2011 of sex trafficking and related counts and sentenced to 50 years imprisonment.
- In a timely 28 U.S.C. § 2255 petition, Sawyer raised eight claims; Count II alleged ineffective assistance of counsel for advice to reject a 15-year plea offer.
- Sawyer attached affidavits from his mother and grandmother stating they were told about a 15‑year offer and that counsel advised rejection.
- The government disputed that any plea offer was made and argued the claim was conclusory.
- The district court denied the § 2255 petition without an evidentiary hearing, calling the allegations unsubstantiated; Sawyer appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion by denying an evidentiary hearing on Sawyer's ineffective-assistance claim concerning a plea offer | Sawyer: counsel advised rejection of a 15-year plea; he would have accepted; affidavits from family corroborate | Government: petitioner’s allegation is conclusory; no evidence a formal plea offer was ever made | Court vacated and remanded for an evidentiary hearing — affidavits and record did not conclusively show no offer; district court erred in denying a hearing |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes two‑prong ineffective-assistance test)
- Lafler v. Cooper, 566 U.S. 156 (Sixth Amendment right to competent counsel in plea bargaining; Strickland applies)
- Foster v. United States, 735 F.3d 561 (standard for prejudice when plea rejected: reasonable probability offer would have been accepted and accepted by court)
- Boulb v. United States, 818 F.3d 334 (standard of review for denying evidentiary hearing on §2255)
- Hill v. Tangherlini, 724 F.3d 965 (courts may not discard self-serving declarations solely because they are from interested parties)
- Payne v. Pauley, 337 F.3d 767 (same)
- Martin v. United States, 789 F.3d 703 (petitioner's conclusory plea-offer allegations insufficient where unsupported)
- Gallo-Vasquez v. United States, 402 F.3d 793 (same)