United States v. Cota-Becerra, 1:08-cr-00072

Cota-Becerra was indicted in 2008 on conspiracy to distribute and multiple methamphetamine distribution counts.
After several withdrawals, James B. Obie represented him; 851 information was filed and withdrawn twice.
On June 11, 2009, Cota entered an open guilty plea to all counts; presentence report favored 5–15 kg and two enhancements.
Sentencing yielded a base level with total offense level 42, advisory range 360 months to life, and concurrent 360-month sentences.
The Ninth Circuit affirmed the conviction in 2010; Cota’s §2255 motion was filed January 2012 alleging ineffective assistance and coercion.
The district court denied the motion, finding the plea voluntary and the sentencing evidence adequate; no certificate of appealability issued.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the guilty plea voluntary and intelligent?	Cota contends coercion/misadvice by counsel rendered plea involuntary.	Obie properly advised and the plea was knowingly entered.	Plea found voluntary and intelligent; claims denied.
Did counsel render ineffective assistance regarding Alford/no-contest pleading and factual basis?	Counsel failed to negotiate an Alford plea and challenged the factual basis.	Factual basis sufficient; no ineffective assistance.	Factual basis adequate; no ineffective assistance established.
Was drug quantity determinations at sentencing reasonable?	Disputed the 5–15 kg range used for base offense level.	Evidence supported the 5–15 kg finding.	Quantity supported by testimony; claim denied.
Do remaining Strickland/related claims have merit?	Other alleged deficiencies in representation and procedure.	No meritorious ineffective-assistance claims beyond the pleaded issues.	All remaining claims denied; COA denied.

Blackledge v. Allison, 431 U.S. 63 (U.S. 1977) (solemn statements in court carry presumption of accuracy)
Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (plea conclusions affect ineffective-assistance analysis)
North Carolina v. Alford, 400 U.S. 25 (U.S. 1970) (no constitutional error in accepting guilty plea while maintaining innocence under certain conditions)
Brady v. United States, 397 U.S. 742 (U.S. 1970) (plea is not involuntary if entered to avoid harsher outcomes; mischaracterization is considered)
Iaea v. Sunn, 800 F.2d 861 (9th Cir. 1986) (gross mischaracterization of outcomes and erroneous sentencing advice can create deficient performance)
Calderon v. United States Dist. Court, 98 F.3d 1102 (9th Cir. 1996) (preliminary review standard for § 2255 motions)
Clay v. United States, 537 U.S. 522 (U.S. 2003) (finality and time limits considerations for § 2255 motions)