United States v. Joshua Beason, 21-5543

Background

June 28, 2019: Beason and two accomplices committed three armed convenience-store robberies; Beason confessed at a hospital and was indicted on three Hobbs Act robbery counts (18 U.S.C. §1951) and three §924(c) firearm counts.
While in pretrial detention Beason spoke daily with his aunt (his cousin Williams’ mother); the government recorded those calls and provided them to defense; the aunt allegedly pressured Beason to take responsibility and exonerate Williams.
The government offered a plea conditioned on cooperation; Beason refused to cooperate and insisted on pleading guilty without a deal; defense counsel warned Beason that his family was "throwing [him] under the bus."
At the change-of-plea hearing the judge and attorneys held a chambers conference (Beason absent) expressing concern that the aunt was coercing him; back in open court the judge asked only the standard Rule 11 voluntariness questions, and Beason denied promises, threats, or coercion and said his plea was voluntary.
The district court accepted the plea and sentenced Beason to 41 months on the Hobbs Act counts consecutively to the mandatory 252-month §924(c) term, for a total of 293 months; Beason appealed arguing his plea was involuntary/Rule 11 was violated and that his sentence was substantively unreasonable.
The Sixth Circuit majority (Kethledge, joined by Rogers) affirmed both the plea and sentence; Judge Clay dissented, arguing the court committed a Rule 11 error by failing to address alleged coercion in open court and would vacate the plea.

Issues

Issue	Plaintiff's Argument (Beason)	Defendant's Argument (Government/Majority)	Held
Voluntariness of guilty plea / Rule 11 compliance	Aunt coerced Beason to plead; court should have made a fuller, in‑court inquiry into coercion; plain error warrants vacatur	Record shows Beason knowingly and voluntarily pled guilty: he denied coercion on the record, counsel advised him, and the court addressed him personally under Rule 11	Majority: No plain error; plea was knowing, voluntary, and Rule 11 requirements satisfied (dissent would vacate)
Substantive reasonableness of sentence	293 months is excessive	252 months of the term were statutorily mandatory; district court imposed low-end Guidelines on remaining counts and considered §3553(a) factors	Majority: No abuse of discretion; sentence not substantively unreasonable

Key Cases Cited

Brady v. United States, 397 U.S. 742 (1970) (plea voluntariness evaluated under the totality of circumstances)
McCarthy v. United States, 394 U.S. 459 (1969) (Rule 11 procedures protect plea voluntariness; noncompliance can require vacatur)
Haynes v. Washington, 373 U.S. 503 (1963) (courts must consider all relevant circumstances in voluntariness inquiry)
Puckett v. United States, 556 U.S. 129 (2009) (plain-error standard requirements for unpreserved errors)
United States v. Webb, 403 F.3d 373 (6th Cir. 2005) (plea must be knowing, voluntary, and intelligent)
United States v. Pitts, 997 F.3d 688 (6th Cir. 2021) (plain-error review for unpreserved Rule 11 objections)
United States v. Vonner, 516 F.3d 382 (6th Cir. 2008) (Guidelines-range sentences are presumptively reasonable)
United States v. Coppenger, 775 F.3d 799 (6th Cir. 2015) (abuse-of-discretion standard for substantive-reasonableness claims)
United States v. Rayyan, 885 F.3d 436 (6th Cir. 2018) (substantive-reasonableness challenges assert that a sentence is too long)
United States v. Robinson, 892 F.3d 209 (6th Cir. 2018) (standards for when a court abuses discretion in sentencing)
United States v. Monie, 858 F.3d 1029 (6th Cir. 2017) (plain-error review where Rule 11 objections were not raised below)