United States v. Mayo: No Prejudice from Counsel’s Erroneous Career-Offender Advice Absent Plea Involuntariness

Introduction

In United States v. Christopher Mayo, No. 23-13278 (11th Cir. Mar. 7, 2025), the Eleventh Circuit addressed whether a defendant’s attorney rendered ineffective assistance by failing to advise him of a looming career offender sentencing enhancement and by allegedly coercing him into signing a plea agreement. Christopher Mayo had pleaded guilty to possession of methamphetamine with intent to distribute under 21 U.S.C. § 841(a)(1), (b)(1)(C). After the district court’s Presentence Investigation Report (“PSR”) classified him as a career offender—raising his Guidelines range from roughly 80 months to over 200 months—Mayo moved to withdraw his plea, contending ineffective assistance of counsel. The district court denied relief, and on appeal the Eleventh Circuit affirmed, finding no prejudice under Strickland v. Washington.

Summary of the Judgment

Mayo pleaded guilty to a § 841(b)(1)(C) methamphetamine offense, having faced a higher mandatory minimum before a superseding information was filed.
At the change-of-plea colloquy, the district court informed him of the maximum 20-year sentence and warned that he could not withdraw his plea if the advisory Guidelines range exceeded expectations.
Months later, the probation office deemed Mayo a career offender, producing a Guidelines range of 210–240 months.
Mayo moved to withdraw his plea, claiming (a) counsel failed to advise him of the career-offender enhancement and (b) counsel coerced him into signing the plea agreement prematurely.
After an evidentiary hearing at which both Mayo and his former lawyer testified, the district court found Mayo’s plea knowing, voluntary, and supported by close assistance of counsel.
On appeal, the Eleventh Circuit affirmed, holding Mayo could not demonstrate Strickland prejudice because the record showed the court had fully informed him of the maximum sentence and he repeatedly acknowledged voluntariness.

Analysis

Precedents Cited

Strickland v. Washington (466 U.S. 668, 1984) – Established the two-pronged test for ineffective assistance: deficient performance and prejudice.
Hill v. Lockhart (474 U.S. 52, 1985) – Clarified that, in the guilty-plea context, prejudice requires a reasonable probability that, but for counsel’s errors, the defendant would not have pled guilty.
United States v. Pease (240 F.3d 938, 2001) – Held that a court’s independent advisal of the maximum statutory sentence cures any misadvice by counsel about potential sentence length.
United States v. Bradley (905 F.2d 359, 1990) – Rejected plea withdrawal based solely on counsel’s incorrect sentencing estimate where the court had informed the defendant of the true maximum penalty.
United States v. Lagrone (727 F.2d 1037, 1984) – Stated that reliance on counsel’s professional judgment in pleading guilty precludes a coercion-based ineffective assistance claim.
Gomez-Diaz v. United States (433 F.3d 788, 2005) – Mixed question of law and fact standard for IAC review on appeal.
United States v. Franklin (694 F.3d 1, 2012) and Verbitskaya (406 F.3d 1324, 2005) – Recognize that a sufficiently developed record on ineffective assistance may be reviewed directly rather than via § 2255.

Legal Reasoning

Applying Strickland, the Eleventh Circuit first noted that Mayo bore the burden of proving both counsel’s deficiency and resultant prejudice. Even assuming counsel erred by not warning about the career-offender guideline, Mayo could not show prejudice under Hill v. Lockhart, as the court had repeatedly advised him of the statutory maximum (20 years) and warned that the advisory Guidelines range could differ from counsel’s estimate. Mayo swore under oath at the plea hearing that he understood these points, that no one had forced him, and that he had reviewed—and signed—the plea agreement voluntarily. Those repeated acknowledgments foreclosed a finding that he would have refused the plea and insisted on trial absent counsel’s misadvice. His coercion argument similarly failed because the record showed the district court made specific inquiries into voluntariness, to which Mayo responded negatively.

Impact

This decision underscores the high bar for establishing prejudice in guilty-plea challenges based on sentencing advice. Trial courts’ thorough plea colloquies—explicitly stating the maximum statutory penalty and warning that advisory Guidelines predictions may be unreliable—will insulate plea agreements from collateral attack, even where counsel’s performance may have fallen short. Defense lawyers should still discuss potential enhancements like career-offender status, but this case confirms that the court’s own advisals carry controlling force in measuring voluntariness and prejudice.

Complex Concepts Simplified

Career Offender Enhancement: A Guidelines rule that raises a defendant’s offense level if he has two prior felony convictions for a crime of violence or controlled substance offense and commits a new qualifying offense.
Strickland’s Two-Prong Test: (1) Counsel’s performance must fall below an objective standard of reasonableness; (2) the defendant must show a reasonable probability that, but for counsel’s errors, the outcome would have been different (e.g., no guilty plea).
Presentence Investigation Report (PSR): A document prepared by probation officers detailing a defendant’s criminal history, offense conduct, and sentencing range under the federal Sentencing Guidelines.
Superseding Information: A revised charging document that alters or narrows the scope of a defendant’s criminal exposure—here reducing the statutory maximum from 40 to 20 years by removing the five-gram methamphetamine allegation.

Conclusion

United States v. Mayo reaffirms that defendants seeking to withdraw guilty pleas on ineffective-assistance grounds face an uphill battle unless they can demonstrate both counsel’s deficient performance and resulting prejudice. Even where counsel misestimates a sentencing enhancement like career-offender status, a thorough plea colloquy advising the defendant of the statutory maximum and the advisory nature of Guidelines predictions will ordinarily preclude a showing of prejudice. This ruling cements the primacy of the district court’s own advisals in preserving plea voluntariness and upholds the integrity of the plea process against collateral attack.