United States v. Quinn Goffigan
691 F. App'x 707
4th Cir.2017Background
- Defendant Quinn Ausidi Goffigan pled guilty pursuant to a written plea agreement to possession with intent to distribute crack cocaine in violation of 21 U.S.C. § 841.
- The district court imposed a downward variance sentence of 240 months' imprisonment.
- Counsel filed an Anders brief asserting no meritorious appeal but questioning the validity of the guilty plea; Goffigan did not file a pro se brief.
- The Government moved to dismiss the appeal based on Goffigan’s appellate-waiver in the plea agreement.
- The panel declined to dismiss because a valid appellate waiver does not bar a claim that a plea was not knowing or voluntary.
- The court reviewed the Rule 11 plea colloquy for plain error and concluded the district court substantially complied with Rule 11 and the plea was valid; judgment affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of appellate waiver | Waiver bars appeal of conviction | Waiver invalid as to plea challenge; plea may not have been knowing/voluntary | Waiver upheld generally, but does not bar challenge to plea voluntariness; Gov’t motion to dismiss denied on that ground |
| Validity of guilty plea under Rule 11 | Plea may have been unknowing/unvoluntary (challenge raised by counsel) | District court substantially complied with Rule 11; plea and waiver were knowing and voluntary | On plain-error review, Rule 11 compliance was substantial and plea was valid |
| Standard of review for waiver and plea challenge | N/A (procedural) | Court should review waiver de novo and plea-colloquy for plain error since no withdrawal motion was filed | Reviewed waiver de novo; plea reviewed for plain error; conclusion supports affirmation |
| Scope of appellate review under Anders | Counsel certified no meritorious issues beyond plea validity | Court must independently review record under Anders | Independent review found no meritorious issues outside waiver; district court judgment affirmed |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (establishes counsel’s duty to file brief identifying any non-frivolous issues and the court’s obligation to review the record)
- United States v. Copeland, 707 F.3d 522 (4th Cir. 2013) (review waiver validity de novo and enforce valid waivers covering the asserted issues)
- United States v. Johnson, 410 F.3d 137 (4th Cir. 2005) (appellate waiver does not bar a challenge that a plea was not knowing or voluntary)
- United States v. DeFusco, 949 F.2d 114 (4th Cir. 1991) (valid plea requires a sufficient factual basis and Rule 11 compliance)