United States v. David Williams, III
811 F.3d 621
| 4th Cir. | 2016Background
- David J. Williams III and Kristin D. Williams pled guilty to one count of conspiracy to possess and distribute cocaine and cocaine base in separate Rule 11(c)(1)(C) plea agreements.
- Each plea stipulated to a sentence of 120 months imprisonment; the district court imposed that sentence.
- Appellate counsel filed Anders briefs questioning (1) whether the district court complied with Rule 11 during plea colloquies and (2) whether Kristin Williams’s 120-month sentence was reasonable.
- The government defended the plea acceptance and the stipulated sentences.
- The Fourth Circuit affirmed the convictions, and dismissed Kristin Williams’s appeal of her sentence for lack of jurisdiction because her plea agreement did not expressly base the stipulated sentence on the Sentencing Guidelines.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court complied with Rule 11 when accepting the guilty pleas | Anders counsel argued possible Rule 11 defects in the plea colloquies | Government: Rule 11 requirements were satisfied | Court: Rule 11 colloquies complied; conviction challenges rejected |
| Whether the appellate court can review the reasonableness of a sentence imposed under a Rule 11(c)(1)(C) stipulated plea | Kristin argued sentence reviewable and possibly unreasonable | Government: stipulated 120-month sentence not reviewable because not based on Guidelines | Court: No jurisdiction to review sentence because plea did not expressly use Guidelines to set term; appeal dismissed |
Key Cases Cited
- Freeman v. United States, 131 S. Ct. 2685 (2011) (held a Rule 11(c)(1)(C) sentence is reviewable under certain circumstances where the agreement expressly bases the term on the Guidelines)
- Anders v. California, 386 U.S. 738 (1967) (procedural framework for counsel filing brief asserting no meritorious appeal)
- United States v. Brown, 653 F.3d 337 (4th Cir. 2011) (applied Freeman to hold a Rule 11(c)(1)(C) sentence not reviewable where the plea did not expressly rely on Guidelines)
- POM Wonderful LLC v. Coca-Cola Co., 134 S. Ct. 2228 (2014) (principle of expressio unius est exclusio alterius cited to interpret statutory scope)