Unreported / Non-Citable
Background
Stephen Williams moved under 28 U.S.C. § 2255 to vacate or correct his federal sentence. His plea agreement contained a collateral-attack waiver, and his requested recalculation relied on a later Sentencing Guidelines change.
The Court’s Holding
The court denied relief and a certificate of appealability. It enforced the knowing collateral-attack waiver and concluded that a nonretroactive guideline amendment did not create a cognizable basis to recalculate the sentence under Section 2255. The asserted error was neither a constitutional violation nor a fundamental miscarriage of justice.
Key Takeaways
- Sentence challenge is denied because the plea waiver is enforceable and the cited guideline change is not retroactive.
- The ruling turns on the governing legal standard and the specific evidentiary record, not labels alone.
- Practitioners should preserve a clear, fact-linked record for review and remedy.
Why It Matters
Plea waivers often foreclose later guideline-based challenges, and a later amendment matters only if the governing authorities make it retroactive through the proper mechanism. Defense counsel should preserve exceptions expressly and explain the lasting reach of collateral-review waivers before a plea is entered.