MARCUS, Circuit Judge:
Appellant Edward Dell appeals the district court's denial of his 28 U.S.C. § 2255 motion — one in a series of attempts, some more successful than others, to reduce his sentence for committing several drug offenses in violation of 21 U.S.C. §§ 841(a)(1) and 856. At the heart of this appeal is whether Dell's defense counsel was constitutionally ineffective for failing to argue, either during sentencing or on direct appeal...
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