U.S. at 59, 106 S.Ct. 366. The Hill standard, however, applies when a defendant seeks to invalidate a plea post-sentence. To require a defendant to satisfy the prejudice prong of Hill in order to withdraw a plea based on counsel’s erroneous advice eviscerates the distinction between a motion to withdraw a plea made pre-sentence and a post-sentence challenge to a plea. Such an interpretation of ‘fair and just’ renders the rule nothing more than an expedited hearing on a challenge to the voluntariness of a plea. A fair reading of the broad language of Rule 11(d)(2)(B) ... establishes that a defendant need not prove that his plea is invalid in order to meet his burden of establishing a fair and just reason for withdrawal. Ortega-Ascanio, 376 F.3d at 884; see also Garcia, 401 F.3d at 1012 (<HOLDING>). Thus, a defense counsel’s erroneous advice
holding that if a state case explicitly states that the state standard is more favorable to the defendant than the federal standard the federal claim is considered adjudicated below when the state standard is applied holding that jackson standard is only standard to use when determining sufficiency of evidence holding that the  fair and just reason standard is simply more generous than the standard for determining whether a plea is invalid holding that the standard of review for an award of statutory damages is even more deferential than an abuse of discretion standard holding that the standard for withholding of removal is more demanding than the standard for asylum