United States v. Williams, 5:16-cr-00433

Background

George Williams pleaded guilty on April 21, 2017 to conspiracy to distribute and possess with intent to distribute methamphetamine and cocaine; his plea agreement preserved only ineffective-assistance-of-counsel (IAC) claims for collateral attack.
Recorded transactions with a confidential source produced two meth shipments (846 g at 43% purity; 287 g at 86% purity) and ~1,985 g of cocaine; a §851 enhancement initially exposed him to mandatory life, but the government agreed not to seek life in the plea deal.
The PSR calculated offense level 33 and criminal-history category V (Guidelines range 210–240 months, capped by statutory maximum); the court adopted the PSR and sentenced Williams to 180 months' imprisonment (below the Guidelines range).
Williams filed a §2255 claiming IAC in four respects: (1) counsel induced his plea by promising <15 years if paid $1,000; (2) counsel failed to contest the PSR’s meth-quantity calculation; (3) counsel failed to contest a 2-level leadership enhancement; and (4) counsel failed to discover that an alleged January 20, 2007 arrest was spurious, which (he argued) improperly increased his criminal-history score.
The government initially misrepresented that Williams waived collateral attacks (the plea expressly reserved IAC claims); the court appointed counsel, ordered supplemental briefing, and the government later produced state records showing there was no January 20, 2007 arrest (but Williams was not in custody then and had in fact committed another offense while on bond).
The court denied the §2255: it found the plea-inducement claim unsupported, confirmed counsel did object to meth quantity and leadership enhancements (and those objections were meritless), acknowledged the PSR overstated criminal history but held Williams showed no Strickland prejudice because his sentence was below even the corrected Guidelines range and further reduction was not reasonably probable.

Issues

Issue	Plaintiff's Argument (Government)	Defendant's Argument (Williams)	Held
1. Plea induced by counsel promising <15 years if paid $1,000	Texts are not a promise inducing the plea; Williams pleaded earlier and under oath; no reasonable probability he would have gone to trial	Counsel guaranteed a sub-15-year sentence in exchange for $1,000 and thus induced plea	Denied — texts occurred after plea, no specific pre-plea promise, plea statements under oath control; no prejudice shown
2. Counsel failed to challenge meth-quantity in PSR	Counsel did object; Guidelines direct using mixture or pure weight, whichever yields higher offense level, so PSR calculation was correct	Counsel failed to investigate; PSR used "actual" meth weight (363.78 g) instead of mixture weight (846 g) improperly	Denied — counsel objected; PSR applied Guidelines correctly (whichever produces greater offense level)
3. Counsel failed to challenge 2-level leadership enhancement (§3B1.1)	Counsel objected; evidence (recorded directions, coordinating courier) supports enhancement	Counsel did not contest leadership and failed to show Williams lacked control over participants	Denied — counsel objected and enhancement was supported by record; no prejudice
4. Counsel failed to discover spurious Jan. 20, 2007 arrest that inflated criminal history	Government concedes PSR overstated criminal history but argues no Strickland prejudice because Williams received 180 months (below corrected Guidelines range) and further reduction is speculative	Failure to uncover records led to extra 3 criminal-history points; with correct Category IV, Guidelines would be lower (188–235 months) and counsel was ineffective	Denied — district court found PSR error but no prejudice: Williams received 180 months (below corrected range) and a further reduction was not reasonably probable given his conduct

Key Cases Cited

Massaro v. United States, 538 U.S. 500 (2003) (IAC claims may be raised in §2255 proceedings even if not on direct appeal)
Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance: deficient performance and prejudice)
Hill v. Lockhart, 474 U.S. 52 (1985) (prejudice standard for IAC claims in plea context: reasonable probability defendant would have gone to trial)
Glover v. United States, 531 U.S. 198 (2001) (any increase in actual imprisonment, however small, can constitute prejudice)
Lafler v. Cooper, 566 U.S. 156 (2012) (reasonableness and prejudice standards for counsel's performance affecting sentencing/outcomes)
Blackledge v. Allison, 431 U.S. 63 (1977) (solemn declarations in open court carry strong presumption of verity in collateral proceedings)
Bond v. Dretke, 384 F.3d 166 (5th Cir. 2004) (requirements for showing counsel-induced plea by promise)
Day v. McDonough, 547 U.S. 198 (2006) (timeliness principles applied to collateral filings)
United States v. Flores, 981 F.2d 231 (5th Cir. 1993) (cause-and-prejudice rule for collateral claims)