What is the test for pleading guilty to section 922(g)(1) of the Criminal Code?

Beaty next contends that there was insufficient evidence to establish the jurisdictional element of section 922(g)(1). Beaty waived this claim by pleading guilty to the charge. See United States v. Mathews, 833 F.2d 161, 164 (9th Cir.1987) (by pleading guilty, defendant admits all averments of fact in the indictment including those that form the predicate for federal jurisdiction).

Finally, Beaty contends that his federal indictment should have been dismissed because he was denied effective assistance of counsel in his prior state court proceedings. Specifically, he argues that if his state attorney had expeditiously pursued a guilty plea to the state charges arising out of the same conduct, no federal charges would have been brought. This claim fails because none of the events leading to the dismissal of Beaty's state charges triggered his right to counsel with regard to his federal prosecution. Cf. United States v. Martinez, 972 F.2d 1100, 1104-05 (9th Cir.1992) (affirming general rule that Sixth Amendment right to counsel is offense-specific and exploring narrow exceptions to rule in context of police interrogation).