United States v. Eric Hutchinson, 670 F. App'x 790

Defendant Eric Ezekial Hutchinson pleaded guilty to possession of a firearm by a convicted felon and was sentenced to 43 months.
Counsel filed an Anders brief asserting no meritorious appeal issues but addressed the validity of the plea and sentence; Hutchinson filed no pro se brief.
The Government did not respond to the Anders brief.
District court conducted a Rule 11 colloquy and accepted the plea after finding it knowing and voluntary with an adequate factual basis.
The district court calculated the Guidelines range without objection, allowed argument and allocution, and imposed a within-Guidelines sentence with an individualized explanation.
The Fourth Circuit reviewed the record under Anders and affirmed the conviction and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of guilty plea under Fed. R. Crim. P. 11	Hutchinson (via Anders brief) raised and addressed whether the plea was knowing/voluntary and supported by a factual basis; suggested possible Rule 11 problems	Government argued the Rule 11 colloquy was adequate and plea was knowing and voluntary	Court held plea was knowing and voluntary; no plain error in Rule 11 hearing and plea stands
Procedural reasonableness of sentence	Hutchinson challenged sentence as possibly procedurally or substantively unreasonable	Government maintained the Guidelines were correctly calculated, §3553(a) considered, and explanation adequate	Court found no procedural or substantive sentencing error; affirmed within-Guidelines sentence

Anders v. California, 386 U.S. 738 (1967) (framework for counsel filing a brief asserting no meritorious issues)
United States v. DeFusco, 949 F.2d 114 (4th Cir. 1991) (requirements of Rule 11 plea colloquy)
Gall v. United States, 552 U.S. 38 (2007) (abuse-of-discretion review for sentencing; procedural and substantive reasonableness)
United States v. Strieper, 666 F.3d 288 (4th Cir. 2012) (presumption of substantive reasonableness for within-Guidelines sentences)