Spiller v. U.S.

Dist. Ct. did not err in dismissing defendant’s habeas petition that challenged his guilty pleas to drug and firearm charges, after alleging that his trial counsel was ineffective during plea-bargaining process. Under govt.’s proposed plea agreement, defendant was required to plead guilty to drug distribution charge, agree that conduct underlying other counts was relevant conduct for sentencing purposes, and stipulate to govt.’s sentencing guideline range calculation, and defendant ultimately entered blind guilty pleas to all counts that reserved right to contest govt.’s sentencing range calculation. Defendant’s trial counsel was not ineffective by counseling defendant to execute blind plea, even though Dist. Ct. eventually sentenced defendant to 240-month term of incarceration that was near govt.‘s 262 to 327-month sentencing range, where: (1) record showed that trial counsel’s blind plea advice was product of legitimate trial strategy, since blind plea allowed defendant to challenge govt.’s sentencing range calculation; and (2) trial counsel believed she could secure better sentence for defendant. Moreover, record showed that trial counsel discussed with defendant his plea options and advised him accordingly.