United States v. Steven Morris, 917 F.3d 818

In 2013 Morris pleaded guilty to conspiracy to distribute cocaine; the PSR identified him as a Sentencing Guidelines career offender based on a 1995 drug conviction and a 2005 Virginia attempted abduction conviction.
The career-offender designation raised Morris’s advisory range from 262–327 months to 360 months–life; after a downward variance he was sentenced to 294 months.
Trial counsel did not object to using the Virginia attempted abduction conviction as a predicate "crime of violence" under U.S.S.G. § 4B1.2; Morris later challenged counsel’s effectiveness in a § 2255 petition.
Morris argued Virginia abduction is broader than generic kidnapping (it allows “deception”) and thus does not qualify under the Guideline’s enumerated-offense or residual-clause prongs.
The district court denied relief, finding counsel’s failure to object was not constitutionally deficient given the state of precedent in 2013; this Court granted COA limited to whether counsel was ineffective and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for failing to object that Virginia abduction is not a "crime of violence" under U.S.S.G. § 4B1.2	Morris: Virginia abduction criminalizes non‑violent deception and thus is broader than generic kidnapping and does not present the ordinary-case risk required by the residual clause.	Government: At the time of sentencing precedent supported treating abduction/kidnapping (including by deceit) as posing a serious risk of physical injury; counsel reasonably declined a novel objection.	Court: Counsel was not deficient under Strickland because existing authority in 2013 did not "strongly suggest" the objection would succeed; affirm denial of § 2255.

United States v. Carthorne, 878 F.3d 458 (4th Cir. 2017) (explains Strickland standard for objections to sentencing enhancements and when precedent "strongly suggests" an argument).
Strickland v. Washington, 466 U.S. 668 (1984) (establishes ineffective assistance two‑prong test).
Harrington v. Richter, 562 U.S. 86 (2011) (strong presumption counsel’s conduct falls within wide range of reasonable professional assistance).
United States v. Mobley, 687 F.3d 625 (4th Cir. 2012) (discusses enumerated offenses commentary and residual‑clause analysis).
United States v. De Jesus Ventura, 565 F.3d 870 (D.C. Cir. 2009) (held Virginia abduction broader than generic kidnapping).
United States v. Flores-Granados, 783 F.3d 487 (4th Cir. 2015) (explains generic‑offense requirement for enumerated offenses and aggravating element need).