Did the lower courts err by relying on a false accusation listed in the PSR, that was verified as false, as the sole basis for not only imposing a statutory maximum of 30 years in prison instead of the recommended 17 years, but then to conclude no prejudice could be shown for § 2255 relief because of that erroneous PSR entry that counsel failed to properly challenge? Should a higher standard of proof apply in such a situation to determine whether to use such conduct at sentencing, as Watts suggested but did not answer?

Did the lower courts err by relying on a false accusation listed in the PSR, that was verified as false, as the sole basis for not only imposing a statutory maximum of 30 years in prison instead of the recommended 17 years, but then to conclude no prejudice could be shown for § 2255 relief because of that erroneous PSR entry that counsel failed to properly challenge? Should a higher standard of proof apply in such a situation to determine whether to use such conduct at sentencing, as Watts suggested but did not answer?