United States v. Brady-Williams, 1:21-cr-00039

Angela Brady-Williams, owner of an IT consulting business, pled guilty to one count of filing a false tax return after providing significantly inflated contract labor expenses on her returns for 2014–2017, resulting in over $2 million in falsely claimed expenses.
She was indicted on four counts of filing false tax returns and was represented by several attorneys before ultimately accepting a plea deal that dismissed three counts in exchange for the plea.
During the plea colloquy, Brady-Williams affirmed under oath that her plea was knowing and voluntary, and that she understood the rights she waived and the potential sentence.
She was sentenced to 33 months imprisonment and over $1 million in restitution to the IRS, without filing a direct appeal.
Brady-Williams filed a pro se motion under 28 U.S.C. § 2255 to vacate her sentence, alleging ineffective assistance and coercion by her final attorney.
The magistrate court addressed whether her counsel’s performance was deficient and whether she was actually innocent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance of counsel	Fishman coerced her into pleading guilty, was unprepared, and misrepresented her options	Counsel’s advice was reasonable under plea circumstances; no evidence of coercion	No deficient performance or coercion; claims contradicted sworn plea statements
Knowing and voluntary plea	Plea was coerced, not voluntary	Plea colloquy and agreement show it was voluntary	Sworn statements at plea colloquy control; plea was voluntary
Prejudice under Strickland standard	But for attorney's conduct, would have gone to trial	No rational person would have rejected plea given evidence and sentencing exposure	No prejudice; plea offered substantial benefit; overwhelming evidence of guilt
Actual innocence	New evidence (Harden affidavit) shows innocence	Affidavit not new, info known at time of plea, contradicts plea admissions	No actual innocence; no newly discovered evidence, claim meritless

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (sets forth the two-prong ineffective assistance of counsel standard)
United States v. Frady, 456 U.S. 152 (U.S. 1982) (high standard for collateral relief under §2255)
Blackledge v. Allison, 431 U.S. 63 (U.S. 1977) (statements made during plea colloquy presumed true in collateral proceedings)
Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (Strickland standard applies to challenge of guilty plea)
Padilla v. Kentucky, 559 U.S. 356 (U.S. 2010) (moving party must show a rational basis to reject plea but for counsel’s errors)
Schlup v. Delo, 513 U.S. 298 (U.S. 1995) (actual innocence claims must present new, reliable evidence)