## Facts

- Swepston was charged with five separate counts of filing false claims for federal income-tax refunds, in violation of 18 U.S.C. § 287.
- He waived indictment and, represented by counsel, pleaded guilty to the five-count information.
- Before accepting the pleas, the district court questioned Swepston to confirm he understood the maximum penalty on each count and that his pleas were voluntary.
- A presentence investigation reported that Swepston had filed many similar false refund claims in multiple locations and had a significant prior criminal record.
- The district court sentenced Swepston to three years’ imprisonment on each count and ordered the sentences to run consecutively (an aggregate term of fifteen years).
- Swepston later moved to vacate or correct his sentence under 28 U.S.C. § 2255, asserting that consecutive sentences were improper and raising additional complaints tied to events before the guilty pleas (including arrest, search and seizure, and interrogation-related allegations).
- The district court denied § 2255 relief without holding an evidentiary hearing.
- Swepston appealed, arguing that the district court erred by imposing consecutive sentences and by denying his postconviction motion without a hearing.

## Issues

1. May a district court impose consecutive sentences when a defendant pleads guilty to multiple counts under 18 U.S.C. § 287, where each count charges a separate false claim?
2. Did the district court properly deny Swepston’s § 2255 motion without an evidentiary hearing where the plea and sentencing record showed the pleas were knowing and voluntary and the remaining allegations were legally insufficient or waived?

## Decision

- The Court of Appeals affirmed the district court’s denial of § 2255 relief.
- The court held that each count charged a distinct violation of 18 U.S.C. § 287, so the district court had authority to impose consecutive three-year sentences.
- The court further held that an evidentiary hearing was not required because the files and records conclusively showed Swepston was entitled to no relief.
- The court rejected collateral claims premised on pre-plea events because voluntary guilty pleas admit the charged offenses and waive prior non-jurisdictional defects.

## Legal Principles

- Separate counts charging separate criminal acts may be punished separately; consecutive sentences are permitted when each count states a distinct offense.
- A knowing and voluntary guilty plea generally waives claims of antecedent, non-jurisdictional error (including many Fourth and Fifth Amendment challenges tied to arrest, searches, or interrogation).
- A district court may deny a 28 U.S.C. § 2255 motion without an evidentiary hearing when the motion, files, and records conclusively show the prisoner is not entitled to relief.
- When accepting a guilty plea, the court must ensure the defendant understands the potential penalties and that the plea is voluntary; a record reflecting those findings strongly limits later collateral attacks.

## Conclusion

United States v. Swepston, 289 F.2d 166 (1961), upheld consecutive sentences totaling fifteen years after guilty pleas to five separate false-claims counts under 18 U.S.C. § 287, and affirmed denial of § 2255 relief without a hearing because the record showed valid pleas and no basis for postconviction relief.
