Warren v. United States, 4:24-cv-00069

Ashley Warren was indicted for conspiracy to distribute at least 50 grams of methamphetamine in violation of 21 U.S.C. §§ 841(a)(1), 841(b)(1)(A), and 846.
She pled guilty without a specified sentencing agreement, allowing the court to impose any lawful sentence.
Warren was sentenced to 120 months of imprisonment by the U.S. District Court for the Eastern District of Tennessee.
She later filed a motion under 28 U.S.C. § 2255 to vacate, set aside, or correct her sentence on the grounds of ineffective assistance of counsel.
Warren argued her attorney coerced her into taking the plea by stating she would otherwise face life imprisonment, and she requested appointment of counsel for the § 2255 proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance of counsel	Counsel coerced Warren into a guilty plea by telling her she'd get life if she didn't plead; claim plea was not voluntary.	Counsel properly informed Warren of possible maximum penalty; no coercion or deficiency in representation.	No ineffective assistance; motion denied.
Voluntariness of plea	Plea was involuntary due to counsel's pressure.	Plea entered knowingly and voluntarily, confirmed by Rule 11 colloquy.	Plea was voluntary.
Government sentencing request	Claimed government requested sentence below 120 months, contradicting the plea outcome.	Record shows no such recommendation by the government.	No merit to the claim.
Appointment of counsel for § 2255	Warren requested court-appointed counsel for motion.	Appointment not automatic; case not complex; Warren able to self-represent.	Counsel not appointed.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong test for ineffective assistance of counsel)
Blackledge v. Allison, 431 U.S. 63 (U.S. 1977) (statements made in open court are presumed true for plea proceedings)
Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (modifies Strickland prejudice prong for guilty plea cases)
United States v. Catchings, 708 F.3d 710 (6th Cir. 2013) (plea must be knowing, voluntary, and intelligent to be valid)
Baker v. United States, 781 F.2d 85 (6th Cir. 1986) (counsel required to inform defendant of maximum potential sentence)