United States v. Peterson Cablay

facts, we do not recount them here, except as necessary to provide context to our

ruling. We have jurisdiction pursuant to 28 U.S.C. § 1291 and § 2253(a). We

affirm.

To prevail on a claim of ineffective assistance of counsel, a defendant must

show “there is a reasonable probability that, but for counsel’s unprofessional errors,

the result of the proceeding would have been different.” Strickland v. Washington,

466 U.S. 668, 694 (1984). “Judicial scrutiny of counsel’s performance must be

highly deferential.” Id. at 689. Counsel “is strongly presumed to have rendered

adequate assistance and made all significant decisions in the exercise of reasonable

professional judgment.” Id. at 690. However, “[a]n attorney’s ignorance of a point

of law that is fundamental to his case combined with his failure to perform basic

research on that point is a quintessential example of unreasonable performance under

Strickland.” Hinton v. Alabama, 571 U.S. 263, 274 (2014).

The safety valve provision allows the district court to sentence a defendant

convicted of certain crimes “without regard to any statutory minimum sentence” if

the court finds that five statutory criteria are met. 18…