United States v. Jeffrey Alan Bourassa, 23-10027

Jeffrey Alan Bourassa pled guilty to conspiracy to commit racketeering in federal district court.
He later appealed, arguing his guilty plea was not knowing, intelligent, or voluntary.
Bourassa specifically claimed undocumented promises may have induced his plea, including potential assurances about better medical treatment.
The district court conducted a plea colloquy and confirmed that Bourassa denied the existence of any such external promises.
The plea agreement signed by Bourassa stated there were no unmentioned promises or agreements.
The appellate court reviewed for plain error, as Bourassa did not object to the Rule 11 process at the trial court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the guilty plea was knowing, intelligent, and voluntary	Bourassa: His plea was potentially coerced by undocumented promises.	Government: The court's inquiry and plea documents established voluntariness.	The guilty plea was knowing, intelligent, and voluntary.
Whether the district court was required to further investigate possible promises regarding medical treatment	Bourassa: The court failed to address possible off-record promises.	Government: Bourassa denied such promises under oath and in the plea agreement.	No plain error: The court was entitled to rely on sworn statements.
Appropriate appellate standard for unobjected-to Rule 11 violations	Bourassa: Implied plain error by the district court.	Government: Must show clear, obvious error affecting substantial rights.	Reviewed for plain error; no clear or obvious error found.
Effect of a plea agreement stating no external promises exist	Bourassa: May have been induced by other assurances.	Government: Such a statement makes reliance on other alleged promises dubious.	The agreement language negates plausibility of undisclosed promises.

United States v. Bushert, 997 F.2d 1343 (11th Cir. 1993) (addresses standard of review for voluntariness of guilty pleas)
United States v. Monroe, 353 F.3d 1346 (11th Cir. 2003) (plain error standard for unobjected-to Rule 11 violations)
United States v. Castro, 455 F.3d 1249 (11th Cir. 2006) (plain error review requirements)
United States v. Hernandez-Fraire, 208 F.3d 945 (11th Cir. 2000) (district court's duty under Rule 11 in guilty pleas)
United States v. Presendieu, 880 F.3d 1228 (11th Cir. 2018) (core concerns of Rule 11 in accepting pleas)
United States v. Medlock, 12 F.3d 185 (11th Cir. 1994) (presumption of truthfulness of plea colloquy statements)
United States v. Al-Arian, 514 F.3d 1184 (11th Cir. 2008) (reliance on plea agreement language disavowing other promises)
United States v. Moriarty, 429 F.3d 1012 (11th Cir. 2005) (requirements for informing defendants of consequences of plea)