United States v. Skyler, 24-40067

Kimondra Damon Skyler pleaded guilty to conspiracy to interfere with interstate commerce by robbery, and using/brandishing a firearm in furtherance of a crime of violence.
He was sentenced to 108 months for the robbery conspiracy and a mandatory consecutive 84 months for the firearm offense, plus five years’ supervised release.
On appeal, Skyler challenged whether his guilty plea was knowing and voluntary, whether the factual basis supported his plea, and whether the government breached its plea agreement by not seeking a sentencing reduction for acceptance of responsibility.
Skyler did not raise these objections at the district court, so plain error review applied at the Fifth Circuit.
The Fifth Circuit reviewed the total record for factual support and the conditions of the plea agreement.

Issue	Skyler's Argument	U.S. Argument	Held
Was the plea knowing and voluntary?	Elements of conspiracy were not recited; thus plea was invalid.	Plea was knowing; Skyler aware of charges and admitted participation.	No plain error; plea was valid.
Was there a sufficient factual basis?	Factual basis did not establish conspiracy or interstate commerce element.	The record allows inference of agreement; minimal interstate commerce effect sufficient.	No plain error; factual basis sufficient.
Did gov't breach plea deal on sentencing?	Gov’t promised full reduction for acceptance and failed to deliver.	Reduction was conditional, not guaranteed; conduct while detained relevant.	No plain error; no breach of plea agreement.

Puckett v. United States, 556 U.S. 129 (plain error standard governs unpreserved errors at the district court)
United States v. Dominguez Benitez, 542 U.S. 74 (defendant must show error affected substantial rights to withdraw plea)
United States v. Ortiz, 927 F.3d 868 (plain error review allows consideration of entire record for factual basis)
United States v. Mann, 493 F.3d 484 (minimal impact on interstate commerce suffices for Hobbs Act cases)
United States v. Robinson, 119 F.3d 1205 (reaffirms de minimis standard for interstate commerce element)
United States v. Watkins, 911 F.2d 983 (conduct while in detention can negate acceptance of responsibility)