United States v. Edward Gladney, 692 F. App'x 185

Gladney, a federal prisoner, pleaded guilty to producing and advertising child pornography and moved under 28 U.S.C. § 2255 seeking relief from that plea.
He alleged his counsel failed to adequately inform him about Dr. Diane Bailey’s psychological evaluation, which might have supported an insanity defense and affected his decision to plead guilty.
On remand, the district court received an affidavit from plea counsel saying she reviewed Dr. Bailey’s report with Gladney and believed he had the information needed to decide whether to plead guilty.
Counsel also testified that Gladney never indicated he misunderstood that his conduct was criminal.
The district court denied § 2255 relief without an evidentiary hearing, finding the record (including counsel’s affidavit and other evidence) contradicted Gladney’s assertions.
The court also found Gladney failed to show a reasonable probability he would have gone to trial and prevailed on an insanity defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an evidentiary hearing was required on Gladney’s claim that counsel failed to inform him about Dr. Bailey’s evaluation	Counsel did not adequately inform Gladney about the report, so a hearing is needed to resolve factual disputes	Record and counsel’s affidavit show Gladney was informed; no hearing required	No abuse of discretion — hearing not required because record supported counsel’s account
Whether counsel’s performance was deficient under Strickland	Counsel’s failure to convey the psychological report deprived Gladney of a viable insanity defense	Counsel reviewed the report with Gladney and he never said he misunderstood criminality	Counsel did not perform deficiently; claim fails
Whether Gladney was prejudiced (would have insisted on trial / had a viable insanity defense)	Had he known the report, he would have pleaded not guilty by reason of insanity and gone to trial	Gladney failed to show an objective likelihood of success at trial or a reasonable probability he would have refused the plea	No reasonable probability of a different outcome; prejudice not proven
Whether the district court could resolve contested factual issues on affidavits alone	Gladney argued competing affidavits required an evidentiary hearing	Court relied on affidavits plus corroborating record evidence, consistent with precedent allowing resolution without a hearing	Denial of relief affirmed; affidavits supported by record were sufficient

United States v. Edwards, 442 F.3d 258 (5th Cir.) (abuse-of-discretion standard for denying evidentiary hearing on § 2255)
United States v. Hughes, 635 F.2d 449 (5th Cir. 1981) (contested factual issues on § 2255 generally require more than unsupported affidavits)
United States v. Batamula, 823 F.3d 237 (5th Cir.) (en banc) (burden to show likelihood of success on insanity defense)
Hill v. Lockhart, 474 U.S. 52 (1985) (standard for prejudice in plea-stage ineffective-assistance claims)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for counsel deficiency and prejudice)