Jackson v. United States, No. 18–15028 (11th Cir. 2019)
Nature of Case: Appellant pled guilty to a federal sex trafficking offense, and received advice from counsel that the plea would not require registration as a sex offender. The offense to which Appellant pleaded guilty does not require registration under Georgia state law, and at the time did not require registration under federal law.
However, subsequently Congress passed the Adam Walsh Act, which mandated sex offense registration for Appellant in light of its retroactive application. Appellant sought to vacate his plea on the grounds of ineffective assistance of counsel, and the trial court denied the petition, but issued a certificate of appealability.
Holding: The 11th Circuit Court of Appeals affirmed, holding that counsel was not ineffective on the grounds that they could not have foreseen subsequent changes to the law that would have impacted Appellant.