United States v. Bruzon-Velazquez, 49 F.4th 23

In April 2017 Bruzón‑Velázquez carjacked David Dubique, drove him to a remote area, and repeatedly shot and killed him; in June 2017 he fired a rifle during an attempted carjacking.
Federal indictments followed for multiple offenses. On January 16, 2020 he accepted a plea agreement: guilty to discharging a firearm in relation to a violent crime resulting in death (18 U.S.C. § 924(c)(1)(A)(iii), (j)) and to attempted carjacking (18 U.S.C. § 2119).
During an extensive plea colloquy (after multiple recesses) he admitted the shootings and affirmed the plea was knowing and voluntary.
Four months later he moved to withdraw the plea alleging surprise, time pressure, and family duress; the district court denied the motion without a hearing.
An amended PSR removed acceptance‑of‑responsibility credit (because he contested guilt), producing a Guidelines range that included life; the court sentenced him to consecutive life imprisonment plus 15 years. He appealed the denial of plea withdrawal and the sentence’s procedural and substantive reasonableness.
The First Circuit affirmed: no abuse of discretion in denying withdrawal and the sentence was procedurally and substantively reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion in denying Bruzón‑Velázquez's pre‑sentencing motion to withdraw his guilty plea	Plea was involuntary because he was surprised by the offer, rushed (time pressure), and pressured by upset family members	Plea was knowing, intelligent, and voluntary; colloquy and multiple recesses show opportunity to consult counsel/family; no credible claim of innocence; delay in moving to withdraw	Affirmed. No abuse of discretion. Plea was voluntary; time pressure and family agitation did not vitiate voluntariness.
Whether the sentence was procedurally and substantively unreasonable	Procedural: Court improperly treated plea as leaving no options; Substantive: sentence (highest Guidelines) was excessive and court gave insufficient weight to mitigation	Court correctly calculated Guidelines, considered §3553(a) factors, relied on plea admissions and facts of brutality; sentence within Guidelines and presumptively reasonable	Affirmed. No procedural error (plain‑error review fails). Sentence is procedurally sound and substantively reasonable; within Guidelines and supported by a plausible rationale.

United States v. Valdez, 975 F.3d 63 (1st Cir. 2020) (standard: abuse of discretion for pre‑sentencing plea‑withdrawal motions)
United States v. Isom, 580 F.3d 43 (1st Cir. 2009) (factors guiding Rule 11(d) withdrawal: voluntariness, reasons, innocence, timing, government prejudice)
United States v. Pellerito, 878 F.2d 1535 (1st Cir. 1989) (time pressures and external stressors usually not dispositive on voluntariness)
United States v. Adams, 971 F.3d 22 (1st Cir. 2020) (family‑related agitation alone insufficient to show duress vitiating plea)
United States v. Marrero‑Rivera, 124 F.3d 342 (1st Cir. 1997) (time pressure common and not inherently coercive)
United States v. Gates, 709 F.3d 58 (1st Cir. 2013) (defendant bound by in‑court plea admissions)
United States v. Flores‑Quiñones, 985 F.3d 128 (1st Cir. 2021) (framework for procedural and substantive reasonableness review)
United States v. Sayer, 916 F.3d 32 (1st Cir. 2019) (district court must avoid significant procedural error and provide explanation for sentence)
United States v. Llanos‑Falero, 847 F.3d 29 (1st Cir. 2017) (within‑Guidelines sentence entitled to a presumption of reasonableness)
United States v. McCoy, 508 F.3d 74 (1st Cir. 2007) (limits of appellate waivers; waiver does not bar appeals outside its scope)