United States v. Felix, 1:21-cr-00472

Oluwatomiwa Akintola participated in a multi-year romance scam, laundering millions from online victims and controlling a shell company to funnel fraud proceeds.
After arrest, Akintola accessed fraud proceeds while on pretrial release, using fake identities.
Akintola pleaded guilty in June 2022 to conspiracy to commit money laundering and was sentenced to 57 months' imprisonment, matching the low end of the stipulated Guideline range.
Akintola moved under 28 U.S.C. § 2255 to vacate his conviction, alleging ineffective assistance by counsel, Speedy Trial Act violations, and that his plea was not knowing and voluntary.
He also sought a sentence reduction under 18 U.S.C. § 3582(c)(2), citing a retroactive Sentencing Guidelines amendment (Amendment 821) that would lower his Guideline range.
The court denied both the motion to vacate and the motion for sentence reduction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance of counsel	Counsel failed to advise about Speedy Trial Act and discussed neither discovery nor offenses; said plea would result in probation or minimal jail	Counsel (and Gov’t): All extensions explained and consented to; discussed discovery and offenses with Akintola	No deficiency found—counsel's conduct was reasonable
Speedy Trial Act violation	Counsel failed to object to improper exclusions benefitting co-defendants	Exclusions were proper for reviewing voluminous discovery, with consent	No violation—time properly excluded and consented to
Plea not knowing/voluntary (Rule 11)	Counsel/court didn’t explain charge or rights; was told would get probation/minimal jail	Court: Full colloquy and explanation at plea; no promises made; understanding confirmed	Plea was knowing and voluntary—no violation of Rule 11
Sentence reduction under Amendment 821	Eligible for lower guidelines range due to zero criminal history points and post-sentence rehabilitation	Gov’t: Seriousness of offense/conduct outweighs eligibility and positive record	Denied—court exercised discretion, citing seriousness of offense and recidivism concerns

Hill v. Lockhart, 474 U.S. 52 (1985) (standards for ineffective assistance claims in the plea context)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel)
United States v. Addonizio, 442 U.S. 178 (1979) (scope of relief under § 2255)
Blackledge v. Allison, 431 U.S. 63 (1977) (statements at plea colloquy presumed to be truthful)
Padilla v. Kentucky, 559 U.S. 356 (2010) (defendant must show rejecting plea would have been rational)