United States v. Taylor
254 F. Supp. 3d 145
D.D.C.2017Background
- Garfield Taylor ran a Ponzi-like securities fraud scheme (2006–2010) through GTI and GAM, defrauding over 150 victims of more than $25 million and withdrawing at least $2.5 million for personal use.
- Taylor pleaded guilty pursuant to a plea agreement to one count of securities fraud and was sentenced to 156 months imprisonment and $28,609,438 restitution.
- The plea agreement preserved Taylor’s right to bring a § 2255 ineffective-assistance claim; a protective order limited copying/transmission of victim-sensitive discovery but allowed counsel-supervised review by Taylor.
- Taylor, represented by two successive court-appointed attorneys, sought to withdraw his plea shortly before sentencing, then withdrew that motion after sentencing and affirmed the voluntariness of his plea under oath.
- Nearly a year after sentencing Taylor filed a pro se § 2255 petition alleging multiple instances of ineffective assistance of counsel and sought broad discovery/modification of the protective order.
- The district court denied the § 2255 motion and all discovery requests, finding Taylor’s claims contradicted by the record and legally insufficient under Strickland; the plea waiver of further discovery also barred the request.
Issues
| Issue | Plaintiff's Argument (Taylor) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Whether plea was involuntary due to counsel encouraging a waiver of IAC claims | Counsel pressured Taylor into a plea that limited his ability to raise IAC | Plea preserved IAC claims; record shows Taylor understood and voluntarily entered plea | Denied — plea agreement expressly preserved IAC claims; Taylor’s in-court statements rebut coercion claim |
| Whether counsel’s performance was deficient in advising plea and failing to investigate | Counsel coerced/failed to investigate, so advice fell below Strickland standard | No specific omitted investigation shown; Taylor admitted understanding plea; strong presumption of adequate assistance | Denied — Taylor did not identify what further investigation would have produced or show deficient performance |
| Whether counsel was ineffective at sentencing for not disputing loss amount sufficiently | Counsel should have reduced loss by amounts returned to investors (e.g., SEC numbers) | Counsel did dispute loss at sentencing; cited evidence does not show lower loss that would change Guidelines bracket | Denied — record shows counsel contested loss; even lower loss would not change the Guidelines enhancement applied |
| Whether Taylor is entitled to broad discovery/grant of modification of protective order | Seeks all government materials (grand jury transcripts, etc.) to search for false evidence or grounds for relief | Discovery waiver in plea agreement and plaintiff failed to show good cause for broad fishing expedition | Denied — no good cause for expansive discovery; plea waiver bars additional discovery |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (standard for ineffective assistance of counsel)
- Lafler v. Cooper, 566 U.S. 156 (IAC principles apply during plea negotiations)
- Missouri v. Frye, 566 U.S. 133 (right to effective counsel in plea negotiation context)
- Farley v. United States, 72 F.3d 158 (D.C. Cir. 1995) (defendant’s plea statements at hearing carry strong presumption of verity)
- Daniels v. United States, 532 U.S. 374 (presumption of regularity in judgments on collateral attack)