United States v. Bryan Behrens

Bryan Behrens, whose sentence on a securities-fraud conviction we affirmed, see United States v. Behrens, 713 F.3d 926, 927 (8th Cir.2013), appeals the district court’s 1 order denying 28 U.S.C. § 2255 relief without an evidentiary hearing. In his motion, Behrens claimed his criminal conviction was void based on an alleged lack of subject matter jurisdiction in light of an order entered in a prior civil proceeding. He also claimed his counsel was ineffective for failing to raise the issue. Because Behren’s subject-matter-jurisdiction and related ineffective-assistance claims are meritless,…