United States v. James Williams, Jr.
690 F. App'x 834
| 4th Cir. | 2017Background
- James Williams, Jr. pled guilty under a plea agreement to conspiracy to possess with intent to distribute and distribute cocaine base (28+ grams) and a quantity of cocaine, in violation of 21 U.S.C. § 846.
- District court sentenced Williams to the statutory minimum: 60 months imprisonment and 4 years supervised release under § 841(b)(1)(B).
- Counsel filed an Anders brief asserting no meritorious issues but questioning the adequacy of the Fed. R. Crim. P. 11 plea colloquy and, separately, the voluntariness of an appellate waiver (the waiver question was not pursued by the government).
- Williams did not move in the district court to withdraw his plea; thus the panel reviewed any Rule 11 errors for plain error.
- The Fourth Circuit reviewed the plea transcript, found the district court substantially complied with Rule 11, and concluded any omissions did not affect Williams’s substantial rights.
- The court affirmed the judgment and explained counsel must inform Williams of his right to petition the U.S. Supreme Court and the procedure for seeking leave to withdraw if counsel deems a cert. petition frivolous.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Rule 11 plea colloquy was adequate | Williams (via Anders) contends the court may have failed to comply with Rule 11 requirements | Government argues the colloquy was adequate; no timely motion to withdraw the plea was made | Court held the district court substantially complied with Rule 11; any omissions did not affect substantial rights (plain-error standard) |
| Whether plain-error review applies | Williams did not move to withdraw his plea, so he implicitly argues errors still warrant relief | Government relies on procedural default to require plain-error review | Court applied plain-error standard and found no reversible error |
| Whether an error affected substantial rights (would Williams have pleaded differently) | Williams must show reasonable probability he would not have pled but for the error | Government contends no reasonable probability exists given the record | Court held Williams did not meet the demanding standard; substantial rights not affected |
| Validity/enforceability of appellate waiver | Counsel questioned voluntariness of waiver | Government did not seek to enforce the waiver | Court declined to decide validity because government did not enforce it |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (1967) (procedural protections when counsel files a brief asserting no meritorious issues)
- United States v. Aplicano-Oyuela, 792 F.3d 416 (4th Cir. 2015) (plain-error review for unchallenged Rule 11 defects)
- Henderson v. United States, 133 S. Ct. 1121 (2013) (requirements for establishing plain error in plea proceedings)
- United States v. Sanya, 774 F.3d 812 (4th Cir. 2014) (showing reasonable probability a defendant would not have pled to establish prejudice)
- United States v. DeFusco, 949 F.2d 114 (4th Cir. 1991) (Rule 11 plea colloquy requirements)
- United States v. Jones, 667 F.3d 477 (4th Cir. 2012) (court will not enforce an appellate waiver sua sponte)