United States v. Kenneth Godsey, 691 F. App'x 122

Kenneth Godsey pled guilty under a Rule 11(c)(1)(C) plea agreement to two counts of mailing threatening communications in violation of 18 U.S.C. § 876(c).
The plea agreement stipulated a sentence range of 60–120 months; the district court imposed 60 months on count 1 and a concurrent 120 months on count 2.
On appeal, counsel filed an Anders brief asserting no meritorious issues but raising (1) whether the court plainly erred in finding Godsey competent to plead and (2) whether counsel rendered ineffective assistance.
The Government did not file a brief and chose not to invoke the appellate waiver in the plea agreement.
At the plea colloquy the district court questioned Godsey about age, education, medication/substance use, and mental-health history; a magistrate judge had found him competent four days earlier.
The Fourth Circuit reviewed for plain error, declined to resolve ineffective-assistance claims on direct appeal, found no plain error as to competency, and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competency to enter guilty plea	Godsey argues the district court plainly erred by accepting his plea despite doubts about his mental state.	The Government (and record) show thorough colloquy and prior magistrate competency finding; no bona fide doubt was ignored.	No plain error; district court properly found Godsey competent to plead.
Ineffective assistance of counsel	Godsey contends counsel provided inadequate representation (specifics not raised on record).	The record does not conclusively show deficient performance or prejudice on its face.	Court declines to reach claim on direct appeal; inappropriate to resolve absent record conclusively showing ineffectiveness.

Anders v. California, 386 U.S. 738 (1967) (procedural protections when counsel seeks to withdraw via an appellate brief)
Henderson v. United States, 568 U.S. 266 (2013) (plain-error standard for Rule 11 defects)
United States v. Nicholson, 676 F.3d 376 (4th Cir. 2012) (court must ensure defendant competence before accepting plea)
United States v. Moussaoui, 591 F.3d 263 (4th Cir. 2010) (defines competency to plead and when court must broaden inquiry)
United States v. Williams, 811 F.3d 621 (4th Cir. 2016) (plain-error review of plea proceedings)
United States v. Benton, 523 F.3d 424 (4th Cir. 2008) (ineffective-assistance claims ordinarily not resolved on direct appeal)
United States v. Baptiste, 596 F.3d 214 (4th Cir. 2010) (same; record must conclusively show ineffectiveness to decide on direct appeal)
United States v. Poindexter, 492 F.3d 263 (4th Cir. 2007) (Anders review; appellate court may independently review record when government waives waiver defense)