Laughlin v. United States, No. 2:17-CV-00085-JRG-CRW (E.D. Tenn. 2020)
Nature of Case: Petitioner pled guilty to a federal kidnapping offense and was not required to register as a sex offender under neither federal law nor by court order. However, Tennessee authorities subsequently required that she register as a sex offender under state law. Petitioner subsequently brought a § 2255 petition to vacate her guilty plea on the grounds that it was not knowing and voluntary, and that she had received ineffective assistance of counsel.
Holding: Federal trial court for the Eastern District of Tennessee denied the petition. While the Court observed that the Petitioner had not waived her right to bring a petition, the Court found that she lost on the merits: sex offense registration was a collateral consequence, and thus her plea was not rendered involuntary nor did her attorney render ineffective assistance.