Tonya Hyles v. United States, 754 F.3d 530

Hyles was convicted of conspiracy to use interstate facilities to commit murder for hire, aiding and abetting murder for hire, possessing a firearm in furtherance of a crime of violence, and conspiracy to deliver a firearm to a felon; she was sentenced to life plus five years and three years of supervised release.
She moved under 28 U.S.C. § 2255 to vacate her sentence on ineffective-assistance grounds; the district court denied without an evidentiary hearing.
This court affirmed the denial on appeal, reviewing de novo the ineffective-assistance issues with predicate facts for clear error.
Hyles claimed trial counsel misadvised her to enter a proffer agreement and to testify under an alleged non-prosecution agreement the attorney allegedly conveyed.
Her grand jury testimony, admitted at trial, included details about her involvement with Carter, the gun, and connections to Tyrese Hyles’s murder plot.
The court concluded she could not show prejudice under Strickland, because the grand jury testimony was cumulative and the trial already included substantial corroborating evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for proffer/non-prosecution guidance	Hyles alleges counsel’s advice to proffer and reliance on a non-prosecution agreement caused prejudice.	Counsel’s conduct was reasonable; had no prejudice since evidence supported guilt with or without the proffer.	No prejudice; Strickland prong fails.
Prejudice from admission of grand jury testimony	Grand jury testimony was crucial and would have been excluded absent counsel’s misadvice.	Testimony was cumulative and harmless; no reasonable probability of different result.	Harmless; no prejudice under Strickland.
Ineffective assistance regarding rejecting plea offer	Counsel should have advised accepting the plea to avoid trial risk.	Counsel’s advice was reasonable; defendant maintained innocence and would not have pleaded guilty.	No deficiency or prejudice; no relief.

United States v. Taylor, 258 F.3d 815 (8th Cir. 2001) (Strickland prejudice standard; reasonable probability of different outcome)
Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (ineffective assistance standard)
Morelos v. United States, 709 F.3d 1246 (8th Cir. 2013) (failure to show prejudice fatal to IAC claim)
Anderson v. United States, 393 F.3d 749 (8th Cir. 2005) (deferential review of counsel’s performance)
Sanders v. United States, 341 F.3d 720 (8th Cir. 2003) (innocence at all stages undermines later IAC plea claims)
Stevens v. United States, 149 F.3d 747 (8th Cir. 1998) (no reasonable probability of guilt admission despite counsel’s advice)