United States v. Mejia-Encarnacion, 887 F.3d 41

Mejía was indicted for two counts of conspiring to possess with intent to distribute cocaine and heroin; agents seized large quantities after coordinated imports from the Dominican Republic.
He was represented sequentially by three attorneys (appointed Federal Public Defender González-Bothwell, retained Rivera, then appointed Zayas, then reappointed González) during pretrial plea negotiations.
Mejía moved to change his plea; at the plea hearing he disclosed daily use of medications for blood pressure, cholesterol, depression, and sleep; the court asked follow-up questions about purpose, timing, and frequency and accepted his guilty pleas after finding him competent.
After pleading guilty, Mejía sought to (1) withdraw his plea and (2) substitute counsel (third motion), asserting lack of trust and ineffective assistance but offering no specific allegations or identified missed motions.
The district court denied the motion to withdraw the plea and denied the third motion for substitute counsel; the court later sentenced Mejía to 121 months’ imprisonment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court failed to adequately inquire about medications under Rule 11, rendering Mejía’s plea involuntary	Mejía: court should have probed names, doses, and effects of medications; failure to do so was reversible error	Govt/Court: follow-up on purpose, timing, frequency and defendant’s clear assurances that he felt fine were sufficient	Held: No plain error — court’s general inquiry and Mejía’s performance in colloquy supported competency and voluntariness
Whether denial of third motion for substitute counsel violated Sixth Amendment	Mejía: lack of trust and asserted conflict of interest required appointment of new counsel	Govt/Court: Mejía gave only vague complaints, no specific alleged conflict or concrete examples of inadequate representation	Held: No abuse of discretion — court’s inquiry was adequate; counsel continued to represent zealously and any breakdown was caused by Mejía’s refusal to cooperate

Cody v. United States, 249 F.3d 47 (1st Cir. 2001) (trial court must inquire when a defendant confirms medication use during plea colloquy)
United States v. Parra-Ibañez, 936 F.2d 588 (1st Cir. 1991) (failure to explore acknowledged prescription medication use can be error when no further inquiry is made)
United States v. Kenney, 756 F.3d 36 (1st Cir. 2014) (no per se requirement to elicit precise drug names and doses during plea colloquy)
United States v. Llanos-Falero, 847 F.3d 29 (1st Cir. 2017) (focus is whether medications affect capacity; limited, targeted questions can suffice)
United States v. Kar, 851 F.3d 59 (1st Cir. 2017) (three-factor test for substitute counsel motions: timeliness, adequacy of inquiry, and whether conflict causes total breakdown)
United States v. Woodard, 291 F.3d 95 (1st Cir. 2002) (disagreement with counsel’s strategic decisions or failure to file meritless motions is not good cause for substitution)
United States v. Myers, 294 F.3d 203 (1st Cir. 2002) (denial of substitution upheld where counsel continued effective representation)
United States v. Reyes, 352 F.3d 511 (1st Cir. 2003) (defendant cannot force new counsel by refusing to communicate with his lawyer)