United States v. Carney, 4:16-cr-00009

Carney was indicted on three counts: felon-in-possession (18 U.S.C. § 922(g)(1)), possession with intent to distribute cocaine base (21 U.S.C. § 841), and possession of a firearm in furtherance of a drug-trafficking offense (18 U.S.C. § 924(c)).
Officers went to Lakisa Adams’s home to arrest Carney; they smelled marijuana, observed Carney concealed, and arrested him; Adams later purportedly consented to a search, yielding drugs, scales, personal items, and a firearm.
At trial Carney admitted ownership during a post-arrest interview; a jury convicted him on all counts and he received 240 months’ imprisonment; the Sixth Circuit affirmed on direct appeal.
Carney filed a timely § 2255 motion asserting (a) the search of Adams’s residence was unconstitutional and (b) trial counsel Brandon Raulston rendered ineffective assistance by failing to move to suppress and failing to investigate adequately; Adams later proffered a handwritten statement denying she consented.
The court held an evidentiary hearing where Raulston explained he interviewed Adams and Carney, concluded Carney lacked a reasonable expectation of privacy in Adams’s home, and made a strategic decision not to file a suppression motion to avoid introducing evidence that would undermine Carney’s defense.
The court denied § 2255 relief, finding counsel’s suppression decision reasonable under Strickland and that Carney failed to show counsel’s performance was objectively unreasonable or prejudicial.

Issue	Carney's Argument	United States' Argument	Held
Whether counsel was ineffective for not filing a motion to suppress	Raulston failed to investigate and should have moved to suppress evidence from Adams’s house	Raulston reasonably investigated and made a strategic choice not to file suppression; decision was within professional norms	Denied — counsel’s decision was reasonable and not objectively deficient
Whether Carney had standing to challenge the search of Adams’s home	Carney had a social-guest expectation of privacy and thus standing to challenge the search	Testimony showed Carney did not live there or exercise sufficient control; standing doubtful	Implicitly rejected — standing was weak and counsel could reasonably avoid pursuing it
Whether failure to file suppression prejudiced the outcome	Suppression would have excluded key physical evidence and likely changed trial result	Even if arguable, introducing evidence of Carney’s connection to the house could have undermined defense; no reasonable probability of a different result shown	Denied — Carney failed to show a meritorious suppression motion and resulting prejudice

Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-prong ineffective-assistance standard: performance and prejudice)
Kimmelman v. Morrison, 477 U.S. 365 (1986) (ineffective-assistance claims based on failure to litigate Fourth Amendment suppression motions)
United States v. Pollard, 215 F.3d 643 (6th Cir. 2000) (factors showing a social guest's meaningful connection to a host's home)
United States v. Heath, 259 F.3d 522 (6th Cir. 2001) (examples of facts supporting a guest's reasonable expectation of privacy)
Smith v. Maryland, 442 U.S. 735 (1979) (framework for expectation-of-privacy analysis referencing Katz)
Caudill v. Conover, 881 F.3d 454 (6th Cir. 2018) (applying Strickland standard in the Sixth Circuit)