United States v. Christopher Stegawski, 687 F. App'x 509

Christopher Stegawski, a physician, was convicted by a jury of conspiring to distribute controlled substances, maintaining a place for distribution, and conspiring to launder money arising from his operation of cash-only pain clinics that routinely overprescribed opioids.
Evidence at trial included undercover purchases, unusually large and addictive medication regimens, ignored abnormal urinalyses, minimal clinical equipment, cash-only rapid appointments, and sexual relationships with patients.
After conviction and a 160-month sentence, Stegawski moved for a new trial claiming trial counsel Michael Cheselka was constitutionally ineffective for not (1) retaining a medical expert to justify prescriptions and (2) cross-examining the government’s medical expert, Dr. Gronbach.
The district court held an evidentiary hearing and denied the new-trial motion; the Sixth Circuit reviewed that denial on appeal (permitting direct review because the district court developed the record).
The Sixth Circuit affirmed, concluding Cheselka’s decisions were reasonable strategic choices: no credible expert willing to support Stegawski was available, and cross-examining the prosecutor’s expert risked reinforcing damaging testimony.

Issue	Stegawski's Argument	Cheselka / Government's Argument	Held
Failure to retain a medical expert	Cheselawski was ineffective for not hiring an expert to rebut prosecution’s medical testimony	No available credible expert would support Stegawski; counsel reasonably declined to call convicted or unreliable experts	Counsel reasonable; no deficient performance or prejudice shown
Failure to cross-examine prosecution expert (Dr. Gronbach)	Counsel should have cross-examined to impeach Gronbach’s urinalysis interpretations and opinions	Cross would likely reinforce Gronbach’s testimony; better to have defendant (a doctor) address the points; strategic decision	Strategic choice within Strickland range; not ineffective assistance

Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel)
Hinton v. Alabama, 134 S. Ct. 1081 (2014) (counsel may be ineffective for failing to seek funds for an expert when based on mistaken belief about availability of funds)
United States v. Gardner, 417 F.3d 541 (6th Cir. 2005) (direct-appeal review of ineffective-assistance claims is normally deferred to collateral review)
United States v. Arny, 831 F.3d 725 (6th Cir. 2016) (district-court development of record can make ineffective-assistance claim reviewable on appeal)
United States v. Munoz, 605 F.3d 359 (6th Cir. 2010) (similar principles on appellate review of post-trial ineffective-assistance claims)
Moss v. Hofbauer, 286 F.3d 851 (6th Cir. 2002) (strategic trial decisions reviewed for reasonableness)
Day v. Quarterman, 566 F.3d 527 (5th Cir. 2009) (rejecting speculative claims that an unnamed expert would have altered outcome)
United States v. Sadler, 750 F.3d 585 (6th Cir. 2014) (context on convictions of pill-mill operators based on similar overprescribing facts)