United States v. Daniel Alexander, 694 F. App'x 205

Daniel Alexander pleaded guilty to conspiracy to distribute oxycodone and alprazolam and was sentenced to 18 months.
His counsel filed an Anders brief asserting no meritorious issues but raising questions about plea voluntariness, denial of a motion to withdraw the plea, and substantive reasonableness of the sentence.
The Government moved to dismiss the appeal based on an appellate-waiver in Alexander’s plea agreement.
The district court had conducted a Rule 11 colloquy when accepting the guilty plea; the transcript was reviewed on appeal.
The Fourth Circuit examined whether the plea was voluntary, whether the district court abused its discretion in denying plea withdrawal, and whether the appellate waiver barred sentence-related challenges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the guilty plea voluntary and knowingly made?	Alexander contended plea may not have been voluntary or made with close assistance of counsel.	Government relied on Rule 11 colloquy and counsel’s effectiveness to show plea was voluntary.	Court held plea was voluntary with competent counsel; conviction affirmed.
Did the district court abuse its discretion by denying motion to withdraw the plea?	Alexander argued denial was improper and withdrawal warranted.	Government argued district court acted within discretion after assessing Rule 11 colloquy and other factors.	Court found no abuse of discretion; denial affirmed.
Is the appellate-waiver valid and does it bar appeal of the sentence?	Alexander challenged sentence but did not show waiver was tainted by constitutional error.	Government moved to dismiss sentence appeal based on knowing and voluntary waiver in plea agreement.	Court held waiver was knowing and voluntary and dismissed appeal as to sentence.
Was the 18-month sentence substantively unreasonable?	Counsel questioned reasonableness of sentence.	Government asserted appeal is barred by waiver; no meritorious sentencing claim presented outside waiver.	Court dismissed sentencing challenge under the valid appellate waiver.

Anders v. California, 386 U.S. 738 (1967) (procedures when counsel asserts appeal is frivolous)
United States v. Davis, 689 F.3d 349 (4th Cir. 2012) (standards for enforcing appellate waivers)
United States v. Thornsbury, 670 F.3d 532 (4th Cir. 2012) (assessing validity of appellate waivers under totality of circumstances)
United States v. Attar, 38 F.3d 727 (4th Cir. 1994) (plea-withdrawal motions alleging constitutional defects in the plea agreement can escape waiver)
United States v. Nicholson, 676 F.3d 376 (4th Cir. 2012) (standards and deference for district court denial of plea-withdrawal motions)
United States v. Moore, 931 F.2d 245 (4th Cir. 1991) (factors relevant to plea-withdrawal motions)