Sehgal v. United States
704 F. App'x 23
| 2d Cir. | 2017Background
- Movant Shashibala Sehgal appealed the district court’s denial of her 28 U.S.C. § 2255 motion seeking to vacate her sentence for ineffective assistance of counsel.
- Sehgal argued counsel rendered ineffective assistance by advising her not to testify (central claim).
- The district court (Feuerstein, J.), who had presided over trial and sentencing, denied relief without a full evidentiary hearing, relying on written submissions and the trial record.
- The district court found Sehgal’s habeas assertions contradicted her prior statements to the court (a sentencing letter and remarks at sentencing).
- Sehgal appealed, challenging the denial of a testimonial evidentiary hearing and the court’s factual resolution.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court abused discretion by denying a full evidentiary hearing on §2255 ineffective-assistance claim | Sehgal: court should have held a full testimonial hearing to resolve factual dispute about decision not to testify | Gov: district court properly resolved the dispute on the record and written submissions without live testimony | Court: No abuse of discretion; testimonial hearing not required where movant’s assertions are contradicted by the record and the trial judge presided over both proceedings |
| Whether district court erred by resolving credibility on written record | Sehgal: credibility required live testimony | Gov: judge may resolve disputed facts on written submissions when record contradicts movant | Court: Permissible to decide disputed facts from written submissions; full hearing not necessary |
Key Cases Cited
- Chang v. United States, 250 F.3d 79 (2d Cir. 2001) (standard of review for §2255 hearing denials)
- United States v. Russo, 801 F.2d 624 (2d Cir. 1986) (procedural context for §2255 review)
- Raysor v. United States, 647 F.3d 491 (2d Cir. 2011) (district court may limit hearing scope and decide facts on submissions)
- Blackledge v. Allison, 431 U.S. 63 (U.S. 1977) (district judges may employ measures to avoid full evidentiary hearings)
- Puglisi v. United States, 586 F.3d 209 (2d Cir. 2009) (district court need not credit movant’s assertions when contradicted by the underlying record)