United States v. Satyen Chatterjee
696 F. App'x 217
9th Cir.2017Background
- Chatterjee pleaded guilty to wire fraud, admitting in the plea agreement and at the plea hearing that he falsely told an investor funds would be used for a mutual fund and not commingled.
- The plea colloquy and plea agreement recited elements of wire fraud and included Chatterjee’s admissions; Chatterjee stated he understood and was satisfied with counsel.
- After sentencing, Chatterjee moved to withdraw his guilty plea arguing the plea was not knowing and that he was actually innocent.
- The district court denied the motion to withdraw and later denied Chatterjee’s motion for reconsideration, which raised ineffective assistance by prior counsel, innocence, and alleged factual inconsistency at sentencing.
- Chatterjee appealed; the Ninth Circuit reviewed both denials for abuse of discretion and affirmed the district court’s rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plea was knowing and voluntary | Chatterjee claimed he did not knowingly enter plea | Plea colloquy and agreement set out elements; Chatterjee showed no confusion | Court: plea was knowing/voluntary; no abuse of discretion |
| Whether factual innocence permits withdrawal | Chatterjee asserted legal innocence and intent to repay victims | Court relied on plea admissions and presumption of veracity from colloquy | Court: innocence claim rejected; admissions control |
| Whether ineffective assistance justified reconsideration | Chatterjee argued prior counsel was ineffective, warranting withdrawal | Argument untimely for reconsideration, Chatterjee said he was satisfied at plea; record shows no deficient performance | Court: not proper basis for reconsideration and fails on merits |
| Whether sentencing findings conflicted with plea facts | Chatterjee argued sentencing would contradict plea facts | Sentencing findings did not contradict plea agreement or colloquy | Court: no inconsistency; reconsideration denied |
Key Cases Cited
- United States v. Mark, 795 F.3d 1102 (9th Cir.) (standard for reconsideration)
- United States v. Yamashiro, 788 F.3d 1231 (9th Cir.) (standards for plea withdrawal and weight of plea colloquy)
- United States v. Hinkson, 585 F.3d 1247 (9th Cir.) (abuse of discretion standard)
- United States v. Ross, 511 F.3d 1233 (9th Cir.) (plea hearing statements carry presumption of veracity)
- United States v. Turner, 898 F.2d 705 (9th Cir.) (unsupported protestations of innocence insufficient)
- United States v. Treadwell, 593 F.3d 990 (9th Cir.) (repayment intent is not a defense)
- United States v. Benny, 786 F.2d 1410 (9th Cir.) (same)
- United States v. Lopez-Cruz, 730 F.3d 803 (9th Cir.) (reconsideration not available for claims that existed earlier but were not raised)
- Strickland v. Washington, 466 U.S. 668 (U.S.) (ineffective assistance standard)