United States v. Jones
395 U.S. App. D.C. 330
| D.C. Cir. | 2011Background
- Jones pled guilty to conspiracy to distribute and possess with intent to distribute 100 grams or more of heroin under 21 U.S.C. §§ 846, 841(a)(1), (b)(1)(B)(i) with a Rule 11(c)(1)(C) agreement calling for a 60-month sentence.
- Had potential life sentence if tried and convicted on Count One due to prior drug convictions; plea agreement reduced exposure.
- Before sentencing, Jones moved to withdraw the guilty plea, claiming he misunderstood the plea to be for possession/sales rather than conspiracy.
- The district court denied withdrawal, and sentenced Jones to 60 months; co-defendants and cooperators were later sentenced.
- During sentencing, the court addressed competency, received a psychologist’s report (which Jones refused to participate in), and concluded Jones was competent.
- On appeal, the circuit reviews the district court’s denial of withdrawal, and remands an ineffective-assistance claim for an evidentiary hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion denying withdrawal of plea for a fair and just reason | Jones asserts a fair and just reason existed to withdraw the plea. | Jones argues the court erred by denying withdrawal without clear basis. | No abuse of discretion; no viable innocence claim and no taint. |
| Whether a competency hearing was required before denying withdrawal | Jones contends a competency exam/hearing was warranted given recommendations. | Court reasonably concluded Jones was competent based on observations and refusals to cooperate. | No abuse of discretion; no reasonable cause for a competency hearing. |
Key Cases Cited
- United States v. Curry, 494 F.3d 1124 (D.C. Cir. 2007) (three-factor test for withdrawal before sentencing, taint most important)
- United States v. Hanson, 339 F.3d 983 (D.C. Cir. 2003) (taint factor not dispositive; waiver of right to withdraw)
- United States v. Shah, 453 F.3d 520 (D.C. Cir. 2006) (uncommon to reverse; standards for withdrawal)
- United States v. Cray, 47 F.3d 1203 (D.C. Cir. 1995) (defendant must show error to succeed on Rule 11 withdrawal)
- United States v. Robinson, 587 F.3d 1122 (D.C. Cir. 2009) (reordered factors; emphasis on taint and innocence)
- United States v. McCoy, 215 F.3d 102 (D.C. Cir. 2000) (burden on defendant regarding innocence claim)
- United States v. Battle, 613 F.3d 258 (D.C. Cir. 2010) (demeanor can bear on competency determinations)
- Drope v. Missouri, 420 U.S. 162 (U.S. 1975) (relevance of defendant’s conduct and mental state to competency)
- United States v. Vachon, 869 F.2d 653 (First Cir. 1989) (communication and competence standards)