Jaymar Stanton Adams v. United States
2017 U.S. App. LEXIS 16242
| 8th Cir. | 2017Background
- Adams pleaded guilty in 2013 to conspiracy to distribute 100 kg or more of marijuana in South Dakota and elsewhere and was sentenced to 60 months and forfeiture.
- Adams signed a plea agreement and a factual-basis statement admitting he agreed to and participated in distribution of 100+ kg of marijuana; he affirmed those statements at the change-of-plea colloquy.
- Adams later filed a § 2255 motion claiming ineffective assistance of counsel: he alleges counsel (Daar) told him to plead blindly, told him to answer “yes” to everything, and that he did not understand the plea or that it covered South Dakota conduct.
- Defense counsel (Daar and local counsel Carper) submitted affidavits disputing Adams’s recantation and confirming a sufficient factual basis and that Adams was instructed to answer truthfully.
- The district court denied the § 2255 motion without an evidentiary hearing, concluding Adams’s allegations were contradicted by the record and inherently incredible.
- The Eighth Circuit affirmed, holding the plea colloquy, signed documents, and record provided a sufficient factual basis and defeated Adams’s ineffective-assistance claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was a sufficient factual basis for Adams’s guilty plea under Rule 11(b)(3) | Adams: admissions referred only to growing in California and did not establish conspiracy to distribute 100+ kg in SD and elsewhere | Govt/Defense: signed factual statement and colloquy admitted conspiratorial conduct involving 100+ kg and that conspiracy occurred in SD and elsewhere | Sufficient factual basis: court may rely on plea agreement, factual statement, and colloquy; admissions supported the charged conspiracy |
| Whether counsel was ineffective in advising/adducing the guilty plea | Adams: Daar coerced blind pleas, told him to answer “yes” to everything, so plea not knowing/voluntary; counsel failed to ensure factual basis | Daar/Carper: counsel explained documents and instructed Adams to answer truthfully; ample factual basis existed | No ineffective assistance: record contradicts Adams’s recantation and shows counsel’s performance was not deficient |
| Whether the district court erred in denying an evidentiary hearing on the § 2255 motion | Adams: conflicting affidavits create genuine dispute requiring live testimony | Govt: Adams’s allegations are contradicted by the record and inherently incredible, so no hearing needed | No abuse of discretion: district court permissibly denied hearing because the record conclusively refuted Adams’s claims |
| Whether Adams was prejudiced by counsel’s performance | Adams: would not have pled guilty but for counsel’s bad advice | Govt: Adams’s sworn statements at plea and documents show he knowingly pleaded; no prejudice shown | No prejudice: strong presumption of verity from plea colloquy defeats prejudice claim |
Key Cases Cited
- Payne v. United States, 78 F.3d 343 (8th Cir. 1996) (standards for reviewing § 2255 and ineffective-assistance claims)
- United States v. Scharber, 772 F.3d 1147 (8th Cir. 2014) (factual-basis inquiry for guilty pleas)
- United States v. Jiminez, 487 F.3d 1140 (8th Cir. 2007) (elements of conspiracy conviction)
- Thomas v. United States, 737 F.3d 1202 (8th Cir. 2013) (when § 2255 allegations can be rejected as contradicted by the record)
- Nguyen v. United States, 114 F.3d 699 (8th Cir. 1997) (plea colloquy statements carry a strong presumption of verity)