United States v. Bahena-Navarro, 678 F.3d 492

Bahena-Navarro, Mexican citizen, entered U.S. illegally in 1980 and was deported in 2004 after prior drug and firearm offenses.
Reentered the U.S. in 2008 and was arrested in Elgin, Illinois in 2009 on domestic violence-related offenses.
A federal grand jury charged him with reentry by a previously deported alien under 8 U.S.C. § 1326(a).
A pretrial motion sought to preclude a collateral attack on the 2004 removal order under § 1326(d); the government produced a signed waiver document with Bahena-Navarro’s fingerprints.
The district court initially denied the motion but later granted it, ruling Bahena-Navarro could not collaterally attack the 2004 removal order.
Bahena-Navarro sought a conditional guilty plea; the district court ultimately rejected the conditional plea due to his lack of knowing and voluntary waiver of trial rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused discretion in rejecting the conditional guilty plea.	Bahena-Navarro argues the court coerced or failed to ensure knowing waiver.	Bahena-Navarro contends he did not knowingly waive rights due to confusion.	No abuse; district court properly assessed knowing waiver.
Whether Bahena-Navarro knowingly waived the right to a jury and to testify.	State argues waiver was explicit and voluntary.	Bahena-Navarro was confused and did not knowingly waive rights.	Defendant did not knowingly waive rights; plea rejection was proper.
Whether the district court needed a fuller statement of rationale for rejecting the plea.	Appellant asserts insufficient explanation on record.	Court adequately explained reasoning in colloquy and opinion.	No requirement for more under the circumstances.

Santobello v. New York, 404 U.S. 257 (Supreme Court, 1971) (plea bargains require honoring promises and discretionary plea decisions)
United States v. Rea-Beltran, 457 F.3d 695 (7th Cir. 2006) (guides abuse-of-discretion review of guilty-plea decisions; factual basis may arise from record)
North Carolina v. Alford, 400 U.S. 25 (Supreme Court, 1970) (acceptance of guilty plea where defendant maintains innocence)
Musa v. United States, 946 F.2d 1297 (7th Cir. 1991) (gives framework for factual basis in plea)
United States v. Hernandez-Rivas, 513 F.3d 753 (7th Cir. 2008) (affirms deferential abuse-of-discretion review of plea decisions)
United States v. Kraus, 137 F.3d 447 (7th Cir. 1998) (requires record-based rationale for rejecting a plea)