United States v. Jeffrey Brady, 675 F. App'x 331

Defendant Jeffrey Kalvin Brady pleaded guilty to conspiracy to distribute cocaine hydrochloride in violation of 21 U.S.C. §§ 841(b)(1)(C), 846.
District court accepted Brady’s plea after a Rule 11 colloquy; Brady did not move to withdraw his plea or preserve a Rule 11 challenge.
Brady was sentenced to 98 months’ imprisonment, a within-Guidelines-range sentence.
Appellate counsel filed an Anders brief certifying no meritorious appeal but raising two questions: Rule 11 compliance and sentence reasonableness.
Brady did not file a pro se supplemental brief. The government urged affirmance.
The Fourth Circuit reviewed for plain error as to the plea and for abuse of discretion as to sentencing and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court complied with Fed. R. Crim. P. 11 in accepting the guilty plea	Brady contended the plea may not have been knowing or voluntary (general challenge raised via Anders brief)	Government argued the plea colloquy substantially complied with Rule 11 and supported a knowing, voluntary plea	Court held substantial compliance with Rule 11; no plain error, plea upheld
Procedural reasonableness of the sentence	Brady questioned whether the court miscalculated Guidelines, failed to consider § 3553(a), relied on erroneous facts, or inadequately explained the sentence	Government maintained the Guidelines were properly calculated and the court followed procedural requirements	Court found no procedural error in sentencing
Substantive reasonableness of the sentence	Brady argued the within-Guidelines sentence might be substantively unreasonable under the totality of the circumstances	Government argued within-Guidelines sentence carries a presumption of reasonableness not rebutted here	Court held Brady failed to overcome the presumption; sentence substantively reasonable
Whether there are any meritorious appellate issues under Anders	Brady (via counsel) suggested potential issues but did not identify meritorious claims	Government urged affirmance and no reversible error	Court performed full review under Anders and found no meritorious issues; affirmed

Anders v. California, 386 U.S. 738 (1967) (procedures for counsel filing a brief asserting lack of meritorious appeal)
United States v. Sanya, 774 F.3d 812 (4th Cir. 2014) (plain-error review for unpreserved Rule 11 challenges)
United States v. Howard, 773 F.3d 519 (4th Cir. 2014) (standard for procedural sentencing review)
Gall v. United States, 552 U.S. 38 (2007) (procedural and substantive reasonableness framework for sentencing review)
United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (presumption of reasonableness for within-Guidelines sentences)