United States v. Miller, 911 F.3d 638

In 1995 Miller transported his 13-year-old adopted daughter across state lines for sexual purposes; charged in 2016 under the Mann Act (18 U.S.C. § 2423(a)).
At the time of the offense (1995) the applicable statute of limitations ran until the victim turned 25; Congress extended that limitations period in 2003 to the life of the child.
Miller’s trial counsel acknowledged the midstream change in law but did not move to dismiss on statute-of-limitations grounds; Miller pleaded guilty in 2017 and was sentenced to 327 months.
On appeal (first raised there), Miller argued his trial counsel was constitutionally ineffective for failing to press a limitations defense.
The First Circuit held the record too undeveloped and the retroactivity of the 2003 amendment too uncertain to decide the ineffective-assistance claim on direct appeal; it affirmed the conviction but left Miller free to pursue §2255 relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an ineffective-assistance-of-counsel claim not raised in the trial court may be heard for the first time on direct appeal	Miller: counsel was ineffective for failing to move to dismiss based on the statute of limitations; record sufficiently clear to decide now	Government: fact-specific claim must be developed in district court (usually via §2255); record here is opaque	Court: Declined to apply Natanel exception; claim may not be considered on direct appeal; affirmed and left claim for §2255 collateral review
Whether the 2003 amendment to 18 U.S.C. §3283 (extending child-sexual-abuse limitations to the life of the child) applies retroactively to 1995 conduct	Miller: the 2003 extension applies because the prior limitations period had not yet expired when Congress amended the law	Government: retroactivity is uncertain; absence of clear congressional instruction and interpretive ambiguity counsel against retrospective application	Court: Did not decide; found retroactivity uncertain and that uncertainty weighs against deciding ineffective-assistance claim on direct appeal

Strickland v. Washington, 466 U.S. 668 (Sup. Ct. 1984) (two-pronged ineffective-assistance test: deficient performance and prejudice)
Hill v. Lockhart, 474 U.S. 52 (Sup. Ct. 1985) (Strickland standard applied to guilty-plea context)
Landgraf v. USI Film Products, 511 U.S. 244 (Sup. Ct. 1994) (framework for assessing retroactive application of statutes)
United States v. Natanel, 938 F.2d 302 (1st Cir. 1991) (narrow exception permitting appellate courts to decide ineffective-assistance claims on direct appeal when facts are undisputed and record adequate)
Toussie v. United States, 397 U.S. 112 (Sup. Ct. 1970) (criminal statutes of limitation construed favoring repose)
Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017) (concluded limitations issue "murky" and analyzed counsel's omission in developed §2255 record)