United States v. Coates, 483 F. App'x 488

Coates pleaded guilty to conspiracy to possess with intent to distribute and to distribute methamphetamine, and to carrying a firearm during and in relation to a drug trafficking crime; the plea included a joint stipulation to a 20-year sentence and a direct-appeal waiver.
The district court accepted the plea and imposed a 20-year sentence (15 years on the conspiracy count, 5 years on the firearm count, to be served consecutively) with five years of supervised release on each count to run concurrently.
Coates moved to withdraw the guilty plea before sentencing; the district court denied requests in February and March 2011, and sentencing followed in March 2011.
An Anders brief was filed indicating no nonfrivolous issues; new counsel substituted, but the panel retained the Anders briefing framework and affirmed the conviction and sentence.
Coates challenged the denial of withdrawal of plea and various other issues on appeal; the court independently reviewed the record and concluded no nonfrivolous issues existed; the sentence-appeal waiver and invited-error principles guided the outcome.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion in denying the guilty-plea withdrawal	Coates asserted innocence or coercion (per Yazzie) and sought withdrawal	Court properly denied withdrawal under Yazzie factors	No abuse; factors did not establish a fair and just withdrawal
Whether the guilty plea was knowing and voluntary	Coates claimed the plea was involuntary due to mental state or pressure	Plea was knowing and voluntary based on colloquy and waiver	Plea was knowing and voluntary
Whether ineffective-assistance claims belong on collateral review and not on direct appeal	Counsel’s coercive/ineffective conduct affected the plea	IAC claims require collateral review given record limitations	IAC claims not decided on direct appeal; addressed as collateral-review issue if pursued
Whether Brady or other evidentiary claims justify relief	Suppression of vehicle-search evidence and DNA evidence	No cognizable Brady violation proven	Brady claim untenable; evidence not shown to be favorable/material
Whether sentencing based on the plea agreement was effectively waived or invited error applied	Sentence length contested despite waiver; potential invited error	Plea agreement bound; waiver forecloses direct challenge; invited-error doctrine applies	Waiver invoked; substantive challenge rejected under invited-error/plea terms

Anders v. California, 386 U.S. 738 (U.S. 1967) (counsel may seek to withdraw when appeal is frivolous and file brief outlining potential issues)
United States v. Yazzie, 407 F.3d 1139 (10th Cir. 2005) (abuse-of-discretion review for pre-sentencing plea withdrawal; seven-factor test)
United States v. Sandoval, 390 F.3d 1294 (10th Cir. 2004) (factors for fair and just reason to withdraw plea before sentencing)
United States v. Hamilton, 510 F.3d 1209 (10th Cir. 2007) (factors for withdrawal of guilty plea; knowing and voluntary assessment)
United States v. Gigley, 213 F.3d 509 (10th Cir. 2000) (plea voluntariness and understanding rights in plea colloquy)
United States v. Carr, 80 F.3d 413 (10th Cir. 1996) (innocence assertion and required support for innocence claims)
Byrum v. United States, 567 F.3d 1255 (10th Cir. 2009) (actual innocence burden and evidentiary showing needed)
Graham v. United States, 466 F.3d 1234 (10th Cir. 2006) (plea colloquy sufficiency and voluntariness assessment)
United States v. Novosel, 481 F.3d 1288 (10th Cir. 2007) (invoked on whether plea agreement-bound obligations constrain review)
Ruiz v. United States, 536 U.S. 622 (U.S. 2002) (plea agreements and timing affect Brady considerations)