United States v. Chambers
2013 U.S. App. LEXIS 5144
| 1st Cir. | 2013Background
- In Oct. 2009 Chambers sold crack cocaine to a government cooperator in Roxbury, leading to a federal indictment under 21 U.S.C. § 841(a)(1).
- On March 14, 2011, Chambers pled guilty pursuant to a binding plea agreement (Rule 11(c)(1)(C)).
- Seven weeks after the plea, Chambers sent a letter seeking leave to withdraw, claiming he felt rushed and coerced.
- Approximately six months later, Chambers formally moved to vacate the guilty plea; the district court denied relief and did not hold an evidentiary hearing.
- At sentencing on Nov. 21, 2011, the court imposed 90 months, within the 72–120 month range set by the Agreement.
- Chambers appeals, challenging voluntariness of the plea, Rule 11 compliance, and the waiver of appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the plea withdrawal properly denied as involuntary? | Chambers contends the plea was involuntary due to misunderstanding the advisory nature of guidelines. | Chambers asserts the change-of-plea colloquy violated Rule 11(b)(1)(M) and rendered the plea involuntary. | No; district court did not abuse discretion; plea knowingly voluntary. |
| Did the court's Rule 11(b)(1)(M) compliance render the plea valid? | Rule 11 requires clarity about guideline advisory status; Chambers argues it was miscommunicated. | The colloquy meaningfully conveyed guideline mechanics; no talismanic statement required. | Yes; the court satisfied Rule 11(b)(1)(M) and the plea was voluntary. |
| Is the waiver of appeal enforceable given the plea and potential invalidity of the Agreement? | Waiver should be disregarded if the Agreement is invalid or miscarriage of justice occurs. | Enforcement of the waiver is permissible unless miscarriage of justice is shown. | Enforceable; no miscarriage of justice shown and Agreement not invalidated. |
| Was an evidentiary hearing necessary on the withdrawal motion? | An evidentiary hearing was warranted to explore alleged coercion and involuntariness. | Record evidence already established the plea's voluntariness; no hearing needed. | No; denial of evidentiary hearing was within the district court's discretion. |
| Did Chambers preserve or waive an ineffective assistance claim? | Ineffective assistance claim could challenge the waiver; exception exists in the waiver. | Ineffective assistance claims must be raised in collateral review, not direct appeal. | Waived for direct appeal; may be raised in a 2255 petition. |
Key Cases Cited
- Nguyen v. United States, 618 F.3d 72 (1st Cir. 2010) (validity of appeal waivers; miscarriage of justice exception)
- Gil-Quezada v. United States, 445 F.3d 33 (1st Cir. 2006) (scope and enforcement of plea waivers)
- Santiago Miranda v. United States, 654 F.3d 130 (1st Cir. 2011) (standards for withdrawing a guilty plea under Rule 11)
- Mercedes v. United States, 428 F.3d 355 (1st Cir. 2005) (knowing and voluntary plea; Rule 11 considerations)
- Negrón-Narváez v. United States, 403 F.3d 33 (1st Cir. 2005) (criteria for withdraw of plea prior to sentencing)
- Ward v. United States, 518 F.3d 75 (1st Cir. 2008) (court need not follow script; factual inquiry tailoring)
- Teeter v. United States, 257 F.3d 14 (1st Cir. 2001) (miscarriage of justice exception; careful scrutiny)
- Ortiz-García v. United States, 665 F.3d 279 (1st Cir. 2011) (effect of waivers; ineffective assistance caveat)
- Mala v. United States, 7 F.3d 1058 (1st Cir. 1993) (procedural limitations on presenting ineffective assistance claims on direct appeal)
- Brady v. United States, 397 U.S. 742 (U.S. 1970) (standard for determining voluntariness; context for plea withdrawal)