United States v. Daniel Taylor
17-5302
| 6th Cir. | Jan 3, 2018Background
- Taylor pleaded guilty under Rule 11(c)(1)(C) to carjacking (18 U.S.C. § 2119).
- Over a month later, Taylor moved to withdraw his guilty plea claiming innocence and seeking trial.
- At the withdrawal hearing, Taylor requested new counsel alleging ineffective assistance and conflict issues.
- District court applied Bashara factors and denied the motion; new counsel was later appointed.
- At sentencing, the district court again denied withdrawal and imposed 156 months’ imprisonment with three years’ supervised release.
- Taylor appeals, challenging the denial of withdrawal as an abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused discretion denying withdrawal | Taylor argues fair and just reason shown under Rule 11(d)(2)(B). | Government contends Bashara factors support denial. | No abuse; failure to show fair and just reason. |
| Timeliness of withdrawal request | Delay was not substantial given circumstances. | Delays of 56 days after plea weigh against withdrawal. | Delay supported denial under Bashara factors. |
| Innocence assertion and plea knowingness | Maintain innocence and dispute counsel adequacy. | Plea was knowing, voluntary, informed; admissions in plea agreement and hearing. | Plea entered knowingly and intelligently; innocence claim unpersuasive. |
| Effectiveness of prior counsel and need for new counsel | Counsel mishandled conflict waiver and discovery issues. | District court found no deficient performance or missing discovery with specifics lacking. | No meaningful error; court did not require different outcome. |
Key Cases Cited
- United States v. Giorgio, 802 F.3d 845 (6th Cir. 2015) (abuse of discretion standard for Rule 11(d)(2)(B) dismissals)
- United States v. Catchings, 708 F.3d 710 (6th Cir. 2013) (Bashara factors guide fair and just reason inquiry)
- United States v. Bashara, 27 F.3d 1174 (6th Cir. 1994) (framework for withdrawal of guilty plea under Rule 11(d)(2)(B))
- United States v. Bazzi, 94 F.3d 1025 (6th Cir. 1996) (Bashara factors are non-exclusive and non-controlling)
- United States v. Dixon, 479 F.3d 431 (6th Cir. 2007) (hastily entered plea not favored for withdrawal)
- United States v. Alexander, 948 F.2d 1002 (6th Cir. 1991) (necessity to show fair and just reason before considering prejudice)