United States v. Wordlaw, 3:21-cr-00223

Antoyn A. Wordlaw was indicted by a federal grand jury on three drug-related counts, and the Federal Public Defender was appointed to represent him.
Pursuant to a plea agreement, Wordlaw pled guilty to possession with intent to distribute methamphetamine (Count I), and the other counts were dismissed at sentencing.
He was sentenced to 234 months’ imprisonment, followed by five years of supervised release, after being designated a career offender under the Sentencing Guidelines due to prior convictions.
Wordlaw’s sentence and the application of the career offender enhancement were affirmed by the Fifth Circuit on appeal.
Wordlaw filed a pro se motion under 28 U.S.C. § 2255, alleging ineffective assistance of counsel for failure to challenge the use of his prior convictions as predicate offenses for the enhancement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance—failure to object to career offender enhancement	Counsel should have argued prior convictions were not qualifying controlled substance offenses	Prior convictions properly qualified; no binding precedent supported objection	Counsel not ineffective; motion denied

United States v. Addonizio, 442 U.S. 178 (1979) (defines when errors are cognizable under § 2255 for fundamental defects)
Strickland v. Washington, 466 U.S. 668 (1984) (establishes the two-prong ineffective assistance of counsel test)
Massaro v. United States, 538 U.S. 500 (2003) (holds ineffective assistance claims may be raised in § 2255 motion regardless of whether raised on direct appeal)
Hill v. United States, 368 U.S. 424 (1962) (explains grounds for collateral attack under § 2255)