United States v. Jonathan Logan
692 F. App'x 722
| 4th Cir. | 2017Background
- Jonathan C. Logan pleaded guilty to bank fraud in violation of 18 U.S.C. § 1344 and was sentenced to 15 months’ imprisonment.
- Appellate counsel filed an Anders brief asserting no meritorious issues but questioning the plea’s validity and sentence reasonableness; Logan filed no pro se brief and the Government did not respond.
- Logan did not move to withdraw his guilty plea; appellate review of the plea colloquy is therefore for plain error.
- The district court conducted a Fed. R. Crim. P. 11 colloquy, informing Logan of charges, penalties, rights surrendered, and establishing a factual basis for the plea.
- At sentencing the court calculated the Guidelines correctly, considered the 18 U.S.C. § 3553(a) factors, allowed allocution, and imposed a within-Guidelines 15-month sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of guilty plea (Rule 11) | Logan (via Anders brief) questioned whether plea was knowing and voluntary | Government and district court maintained plea colloquy satisfied Rule 11 requirements | No plain error; plea was knowing, voluntary, and supported by factual basis |
| Standard of review for unpreserved Rule 11 error | Logan argues possible defects warrant reversal | Appellate court applies plain-error review to unpreserved Rule 11 issues | Plain-error standard applied; no reversible error found |
| Procedural sentencing errors | Logan questioned sentence reasonableness | District court correctly calculated Guidelines and considered § 3553(a) factors | No procedural error in sentencing |
| Substantive reasonableness of sentence | Logan challenged sentence as excessive | Sentence was within Guidelines and individualized; presumption of reasonableness applies | Within-Guidelines sentence presumed and found substantively reasonable |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (1967) (defendant-appointed counsel may file a brief asserting the case is frivolous and request permission to withdraw)
- DeFusco v. United States, 949 F.2d 114 (4th Cir. 1991) (Rule 11 requirements for plea colloquy)
- Massenburg v. United States, 564 F.3d 337 (4th Cir. 2009) (plain-error review for unpreserved Rule 11 claims)
- Henderson v. United States, 568 U.S. 266 (2013) (standard for plain-error review of Rule 11 errors)
- Gall v. United States, 552 U.S. 38 (2007) (abuse-of-discretion review of sentence; procedural and substantive reasonableness framework)
- Louthian v. United States, 756 F.3d 295 (4th Cir. 2014) (presumption of substantive reasonableness for within-Guidelines sentences)