United States v. David Adams
2014 U.S. App. LEXIS 18348
2d Cir.2014Background
- Adams pled guilty to one count of conspiracy to distribute and possess with intent to distribute at least 1,000 kilograms of marijuana under a Plea Agreement.
- Plea entrusts a Stipulated Guidelines Range of 210–262 months with a joint understanding that sentences within/below range are not appealable, subject to certain exceptions.
- Adams underwent heart condition treatment, had a pacemaker implanted, and asserted medications could affect cognitive function at the time of plea.
- Medical records before and after plea showed no clear evidence of medication-induced cognitive impairment; doctors described Adams as alert and oriented.
- At sentencing, the district court considered Adams’s heart condition and health issues but imposed the bottom of the Guidelines range at 210 months, followed by five years of supervised release.
- Adams timely appealed, challenging Rule 11 compliance, the sentence, the appeal waiver, and later seeking potential ineffective-assistance considerations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rule 11 adequacy for medical condition | Adams argues court failed to inquire about heart condition affecting plea. | Adams contends Rule 11 should have probed medications/condition to ensure knowing plea. | No plain-error shown; conviction affirmed. |
| Sentence reasonableness under Gall and related standards | 210 months is substantively unreasonable given medical condition. | Sentence falls within permissible range and properly weighed factors. | Sentence affirmed as reasonable within range. |
| Appeal waiver enforceability | Waiver forecloses appeal of sentence within stipulation range. | Waiver may be unenforceable; merits reviewed anyway. | Waiver issues not dispositive; judgment affirmed. |
| Ineffective assistance of counsel on direct appeal | Counsel ineffectiveness merits consideration on appeal. | Ineffective-assistance claims should be raised in collateral §2255 proceedings. | Claim dismissed without prejudice to §2255 proceedings. |
Key Cases Cited
- Yang Chia Tien, 720 F.3d 464 (2d Cir. 2013) (plain-error standard for Rule 11 in guilty-plea cases)
- United States v. Garcia, 587 F.3d 509 (2d Cir. 2009) (showing prejudice required under plain error)
- United States v. Lora, 895 F.2d 878 (2d Cir. 1990) (strict adherence to Rule 11 when defendant under medication)
- United States v. Rossillo, 853 F.2d 1062 (2d Cir. 1988) (duty to explore mental state when medication present)
- United States v. Kerr, 752 F.3d 206 (2d Cir. 2014) (abuse-of-discretion review for sentencing)
- United States v. Cavera, 550 F.3d 180 (2d Cir. 2008) (en banc standard for substantive reasonableness)
- United States v. Yousef, 327 F.3d 56 (2d Cir. 2003) (Eighth Amendment and length of noncapital sentences)
- United States v. Jones, 531 F.3d 163 (2d Cir. 2008) (district court discretion in sentencing within guidelines)
- United States v. Thavaraja, 740 F.3d 253 (2d Cir. 2014) (deferential standard in evaluating reasonableness)
- Massaro v. United States, 538 U.S. 500 (S. Ct. 2003) (ineffective-assistance claims typically resolved via §2255)