111547P.pdf   06/26/2012  Charles Watson, Jr.  v.  United States
   U.S. Court of Appeals Case No:  11-1547
   U.S. District Court for the Southern District of Iowa - Des Moines   
   [PUBLISHED] [Bye, Author, with Smith and Colloton, Circuit Judges]
   Prisoner case - habeas. Leaving aside the issue of whether Watson's
   plea agreement validly waived his ability to raise an ineffective assistance
   of counsel claim in a future habeas petition and whether such a waiver
   raises a potential conflict of interest for his attorney, Watson's ineffective
   assistance of counsel claim fails on the merits as his sentence was
   determined by the fact that a death occurred from his distribution of
   heroin and not because he admitted that the conspiracy involved fifty or
   more grams of cocaine base; with respect to Watson's claim that his
   attorney failed to properly investigate his involvement in the death, the
   record showed Watson admitted delivering the drugs to the victim on the
   date he died and Watson failed to show how his counsel was ineffective in
   failing to further investigate the matter.