United States v. Alfred Adams, 686 F. App'x 233

Alfred Adams pleaded guilty to conspiracy to possess with intent to distribute heroin and methamphetamine in violation of federal law and was sentenced to 121 months.
Counsel filed an Anders brief conceding no meritorious appeal but raising questions about Rule 11 plea colloquy, a §3B1.1 (aggravating-role) enhancement, and use of a 1995 drug conviction to increase statutory mandatory minimum under §§ 841(b)(1)(B) and 851.
Adams did not file a pro se supplemental brief or move to withdraw his plea in district court.
On review, the Fourth Circuit examined Rule 11 compliance for plain error, reviewed the sentence for procedural and substantive reasonableness, and considered the use of the 1995 conviction for statutory enhancement.
The court concluded the plea was knowing and voluntary with a factual basis, the sentencing calculation and explanation (including the §3B1.1 enhancement) were proper and reasonable, and the 1995 prior conviction could validly be used to enhance the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Rule 11 compliance for plea colloquy	Adams (via counsel) questioned whether the court complied with Rule 11 when accepting the plea	District court substantially complied; omissions were minor and did not affect substantial rights	No plain error; plea knowing, voluntary, and supported by factual basis
Plea voluntariness re: threats/promises	Adams suggests court failed to ask if plea resulted from outside threats/promises	Plea agreement stated it was entire agreement; no evidence of outside promises	Substantial compliance; omission not prejudicial
Sentencing reasonableness and §3B1.1 enhancement	Adams challenged four-level aggravating-role enhancement and overall sentence	District court correctly calculated offense level, criminal history, afforded allocution, and explained sentence	Sentence procedurally and substantively reasonable; within-Guidelines presumption not rebutted
Use of 1995 prior conviction to enhance statutory minimum under §§841 & 851	Adams argued reliance on old conviction was improper (raised first on appeal)	Statute contains no time limit on using prior convictions for enhanced penalties	No error; prior conviction properly used to enhance sentence

Anders v. California, 386 U.S. 738 (U.S. 1967) (procedures for appellate counsel who finds appeal frivolous)
United States v. DeFusco, 949 F.2d 114 (4th Cir. 1991) (Rule 11 plea colloquy requirements)
United States v. Sanya, 774 F.3d 812 (4th Cir. 2014) (plain-error review of Rule 11 where plea withdrawal not preserved)
United States v. McCoy, 804 F.3d 349 (4th Cir. 2015) (abuse-of-discretion standard for sentence reasonableness)
Gall v. United States, 552 U.S. 38 (U.S. 2007) (procedural and substantive reasonableness framework for sentencing review)
United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (presumption of reasonableness for within-Guidelines sentence)