CLICK HERE FOR FULL TEXT
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
SONG GUO ZHENG,
Defendant-Appellant.
   No. 21-3513
Appeal from the United States District Court for the Southern District of Ohio at Columbus.
No. 2:20-cr-00182-1—Algenon L. Marbley, District Judge.
Decided and Filed: March 10, 2022
Before: BATCHELDER, NALBANDIAN, and READLER, Circuit Judges.


_________________________
OPINION
_________________________

NALBANDIAN, Circuit Judge. Song Guo Zheng lied on several applications for National Institute of Health (NIH) funding while employed at some of the country’s largest universities. Zheng pleaded guilty to fraudulently obtaining this federal funding, but on appeal argues that his trial counsel was ineffective by not seeking a downward variance at sentencing given his immigration status. Generally, however, we decline to review ineffective-assistance claims for the first time on direct appeal because the record is inadequate to establish any error. Seeing no reason to depart from this practice, we DISMISS Zheng’s ineffective-assistance claim.