United States v. Ronald Gainey
663 F. App'x 259
| 4th Cir. | 2016Background
- Defendant Ronald Matthew Gainey pleaded guilty pursuant to a written plea agreement to conspiracy to manufacture methamphetamine (21 U.S.C. § 846).
- District court calculated an advisory Guidelines range of 240 months but sentenced Gainey to 175 months (below the range).
- Appellate counsel filed an Anders brief asserting no meritorious issues; the Government declined to file a brief.
- Gainey did not move in district court to withdraw his guilty plea; appellate review of the plea is for plain error.
- Gainey filed a pro se supplemental brief claiming the court permanently barred him from federal benefits; the court made no such ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of guilty plea under Rule 11 | Gainey argues plea was knowing/voluntary (no direct challenge) | Government contends plea was proper; Anders counsel raises no meritorious claim | Court held district court substantially complied with Rule 11; plea knowing and voluntary (no plain error) |
| Standard of review for plea withdrawal | N/A (no motion made) | N/A | Review is for plain error; defendant failed to show plain error affecting substantial rights |
| Procedural reasonableness of sentence | Gainey argues sentence improper? (no preserved challenge) | Government supports sentence as reasonable and below Guidelines | Court found no procedural error: Guidelines calculated correctly, §3553(a) considered, allocution and counsel heard |
| Substantive reasonableness of sentence | Gainey implicitly seeks relief from within-Guidelines sentence | Government argues below-Guidelines sentence is reasonable | Court held 175-month below-Guidelines sentence was substantively reasonable and presumptively so |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (procedures for counsel to raise frivolous-appeal claim)
- United States v. Martinez, 277 F.3d 517 (4th Cir. 2002) (plain-error review when defendant did not move to withdraw plea)
- United States v. Muhammad, 478 F.3d 247 (4th Cir. 2007) (elements and discretionary relief standard for plain error)
- Gall v. United States, 552 U.S. 38 (sentencing review: procedural and substantive reasonableness framework)
- United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (presumption of substantive reasonableness for within-or-below-Guidelines sentences)
- United States v. Montes-Pineda, 445 F.3d 375 (4th Cir. 2006) (rebutting presumption by showing unreasonableness under §3553(a) factors)