United States v. Huey Carter, 795 F.3d 947

Carter sold crack cocaine to a confidential informant; indicted for distribution and later entered a guilty plea pursuant to an agreement that removed a prior-conviction mandatory minimum.
Initially proceeded pro se after Faretta hearing; court investigated but rejected suicide-watch concerns (record showed an in-custody insubordination issue).
At the change-of-plea hearing Carter disclosed he was on Seroquel and "some depression pills." The court asked whether those medications affected his understanding; Carter replied no and answered appropriately throughout the colloquy.
No contemporaneous objection was made, and Carter did not move to withdraw his plea at sentencing; he raised the voluntariness claim for the first time on direct appeal.
Carter argued the district court’s brief medication inquiry violated Rule 11(b) by failing to ensure his plea was knowing and voluntary; the government and court relied on the colloquy and Carter’s performance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a defendant’s disclosure of medication requires expanded Rule 11 inquiry	Carter: court should have pursued a more searching inquiry into type/effect/dosage to ensure voluntariness	Government: limited follow-up plus defendant’s assurances and courtroom demeanor suffice	Court: No error — district court’s follow-up (asking type, effect, and testing understanding) was sufficient
Standard of review for unobjected Rule 11 procedural error	Carter: argues Rule 11 violation warrants reversal	Government: plain-error review applies because no objection was made	Court: Applied plain-error framework but found no error, so analysis ended there
Reliance on defendant’s courtroom demeanor and answers when medication disclosed	Carter: medication may have affected his capacity despite clear answers	Government: court may rely on defendant’s responses, demeanor, and medical history	Court: Permissible to rely on responses and observations when answers show comprehension
Whether failure to ask specific drug names/dosages is required	Carter: First Circuit best practices recommend names/dosages	Government: names/dosages not required; practical inquiry suffices	Court: Not required; courts may use practical judgment and need only ensure drugs did not impair plea

Dominguez Benitez, 542 U.S. 74 (Rule 11 unobjected-to procedural errors reviewed for plain error)
Cotton v. United States, 535 U.S. 625 (plain-error test elements)
United States v. Timbana, 222 F.3d 688 (9th Cir.) (adequacy of mental-state inquiry at plea after competency hearing)
United States v. Cole, 813 F.2d 43 (3d Cir. 1987) (vacated plea where court failed to follow up after drug disclosure)
United States v. Rossillo, 853 F.2d 1062 (2d Cir. 1988) (vacated plea for lack of inquiry after medication admission)
United States v. Lessner, 498 F.3d 185 (3d Cir. 2007) (follow-up inquiry about medication effects can satisfy Rule 11)
United States v. Savinon-Acosta, 232 F.3d 265 (1st Cir. 2000) (best practices: inquire about drug identity, timing, dosage, and effects; but names/dosage not strictly required)
United States v. Kenney, 756 F.3d 36 (1st Cir. 2014) (district court may accept assurances without eliciting name/dosage of each drug)
United States v. Damon, 191 F.3d 561 (4th Cir. 1999) (when medication raises doubt, court must broaden inquiry)
United States v. Browning, 61 F.3d 752 (10th Cir. 1995) (court may rely on defendant’s assurance, counsel’s input, and observations)