Teton v. United States, 4:24-cv-00376

Rydon Clyde Teton was indicted in 2018 on federal charges of second-degree murder and use of a firearm during a crime of violence.
Teton struggled with mental health issues, resulting in two court-ordered competency evaluations; both found him competent for trial.
After multiple attorney changes, Teton pleaded guilty in August 2023 to voluntary manslaughter and the firearm charge, receiving a total sentence of 253 months and 9 days.
Teton did not appeal his conviction or sentence directly but later filed a timely motion under 28 U.S.C. § 2255 to vacate, set aside, or correct his sentence.
Teton claimed ineffective assistance of counsel and various trial court errors, and he requested the appointment of counsel for the post-conviction proceedings.
The government opposed the motion, and the court decided the issues on the written record without oral argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance – § 5K1.1 motion	Sasser failed to seek a downward departure for assistance	No evidence of substantial assistance; motion meritless	No deficiency or prejudice; claim denied
Ineffective assistance – mitigation expert	Counsel failed to have expert testify at sentencing	Written mitigation report used; tactical choice	No deficiency or prejudice; claim denied
Ineffective assistance – witness perjury	Counsel didn’t challenge alleged perjury	Witnesses did not testify; no perjury	Conclusory and unsupported; claim denied
Court errors – sentencing/mental health	Court did not grant departure for mental health	Arguments were made; court avoided 4-level increase	No error; mental health considered; claim denied
Speedy trial rights	Court delayed trial violating speedy trial rights	Delays due to mental health evaluations, attorney changes	No speedy trial violation; claim denied
Consecutive sentences validity	Consecutive sentences are invalid	Required by statute for 924(c) charges	Consecutive sentences required by law; claim denied
Appointment of counsel for § 2255	Petitioner needs counsel for post-conviction relief	No right to counsel for collateral proceedings	No exceptional circumstances to appoint counsel

Harrington v. Richter, 131 S. Ct. 770 (2011) (articulates strong presumption of reasonable professional conduct for ineffective assistance claims)
Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-part test for ineffective assistance of counsel)
Kimmelman v. Morrison, 477 U.S. 365 (1986) (sets high bar for showing gross incompetence by counsel)
United States v. Frady, 456 U.S. 152 (1982) (procedural default doctrine for collateral post-conviction)
Pennsylvania v. Finley, 481 U.S. 551 (1987) (no right to counsel on collateral post-conviction proceedings)
Slack v. McDaniel, 529 U.S. 473 (2000) (standard for certificate of appealability)