United States v. Angelle, 1:17-cr-00148

Defendant Shaquille Denzel Angelle pleaded guilty to Count One of an indictment charging a violation of 18 U.S.C. § 922(g)(1) (possessing firearms after a felony conviction).
The charged conduct occurred on or about August 12, 2017, in the Eastern District of Texas; two 9mm pistols were identified as the firearms involved.
Angelle had a prior felony conviction (Possession of a Controlled Substance, Jefferson County, Texas, Sept. 15, 2014), establishing the § 922(g)(1) predicate.
The plea hearing was conducted by a United States Magistrate Judge under 28 U.S.C. § 636(b)(3) with the defendant’s knowing, voluntary consent and after consultation with counsel.
The Government proffered a factual basis and stipulated it could prove each element beyond a reasonable doubt; defendant agreed the factual basis supported the plea and testified the plea was voluntary and informed.
The magistrate judge recommended the District Court accept the guilty plea, order a presentence report, and adjudge Angelle guilty; defendant retains the right to allocute and to file objections to the recommendation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Authority of magistrate to administer felony guilty plea	Magistrate may conduct plea proceedings as an "additional duty" under 28 U.S.C. § 636(b)(3)	Angelle consented to magistrate; no contrary argument preserved	Magistrate has statutory authority; plea proceeding properly conducted (citing Bolivar‑Munoz)
Competency and voluntariness of plea	Government: Angelle competent, consulted counsel, plea knowing and voluntary	Angelle personally testified plea was knowing, voluntary, and not coerced	Court found plea knowing, voluntary, and not the result of force, threats, or promises
Sufficiency of factual basis for guilty plea	Government proffered testimony and exhibits it would offer at trial and provided a factual basis; stipulated evidence proved each element	Defendant stipulated and agreed factual basis supported elements	Court concluded an independent factual basis exists supporting each essential element of § 922(g)(1) offense
Recommendation and procedural rights on objection	Government recommended acceptance and presentence report; advised of procedure for objections	Defendant may object in writing within 14 days and may allocute before sentencing	Magistrate recommended District Court accept plea and adjudge guilt; warned parties of objection procedure and consequences if none filed

313 F.3d 253 (5th Cir. 2002) (magistrate judges may conduct felony guilty plea proceedings as an additional duty)
857 F.2d 275 (5th Cir. 1988) (failure to object to magistrate recommendations waives de novo review)
79 F.3d 1415 (5th Cir. 1996) (en banc) (objection requirement and appellate review limits for magistrate reports)
711 F.2d 619 (5th Cir. 1983) (district judge must consider actual evidence when a party objects to magistrate findings)
644 F.2d 357 (5th Cir. 1981) (per curiam) (same principle requiring district judge’s independent consideration upon objection)