United States v. Sanchez-Espinoza, 8:15-cr-00156

Issreal Sanchez-Espinoza was indicted for conspiracy to distribute and possession with intent to distribute 500+ grams of methamphetamine; he pled guilty to Count 1 without a plea agreement.
The indictment carried a statutory 10-year mandatory minimum; the Presentence Report found him eligible for the safety valve and the Guidelines range was 70–87 months.
The court sentenced Sanchez-Espinoza to 70 months (the low end of the Guidelines); he did not file a direct appeal.
He then filed a 28 U.S.C. § 2255 motion asserting ineffective assistance of counsel on multiple grounds, including that counsel failed to advise or file an appeal, misadvised about sentencing, failed to secure safety-valve/fast-track relief, and did not present mitigating personal circumstances.
The court held an evidentiary hearing limited to the appeal-rights claim, credited defense counsel’s testimony about his communications and representation, and found no deficient performance or prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel advised defendant of appeal rights and filed an appeal	Government: counsel properly advised and did not file because defendant elected not to appeal	Sanchez-Espinoza: counsel failed to inform him of appeal rights and did not file a requested appeal	Denied — court credited counsel’s testimony; no ineffective assistance on appeal rights
Whether counsel’s advice about likely sentence rendered plea involuntary	Government: inaccurate sentencing predictions do not invalidate plea if statutory max was disclosed	Sanchez-Espinoza: counsel promised a lower sentence than 70 months, so plea was involuntary	Denied — defendant was informed of statutory range and pled knowingly; no showing he would have gone to trial
Whether counsel failed to secure safety-valve or was ineffective regarding criminal-history enhancement	Government: defendant received safety-valve and had no criminal history	Sanchez-Espinoza: counsel’s performance led to an improper enhancement and loss of relief	Denied — record shows safety-valve applied; no enhancement problem attributable to counsel
Whether counsel failed to obtain fast-track (5K3.1) or present personal mitigation	Government: defendant was ineligible for fast-track; counsel presented mitigation reasonably	Sanchez-Espinoza: counsel failed to obtain 5K3.1 and did not present personal circumstances adequately	Denied — fast-track was inapplicable to this offense and no deficient performance shown

Strickland v. Washington, 466 U.S. 668 (establishes ineffective-assistance standard)
Gideon v. Wainwright, 372 U.S. 335 (right to counsel in criminal cases)
Evitts v. Lucey, 469 U.S. 387 (right to effective counsel on first appeal of right)
Kimmelman v. Morrison, 477 U.S. 365 (counsel claim standards in adversary process)
United States v. Andis, 333 F.3d 886 (8th Cir.) (validity of plea and court’s duty to question defendant)
King v. United States, 595 F.3d 844 (8th Cir.) (Strickland application at sentencing)
Quiroga v. United States, 554 F.3d 1150 (8th Cir.) (inaccurate sentencing predictions do not invalidate plea)
Alaniz v. United States, 351 F.3d 365 (8th Cir.) (prejudice standard in plea context)
Sinisterra v. United States, 600 F.3d 900 (8th Cir.) (objective standard for deficient performance)