United States v. Thomas Scotland, 19-4602

Thomas Allen Scotland pled guilty to one count of conspiracy to distribute and possess with intent to distribute cocaine base and cocaine, one count of distribution of cocaine base, and three counts of distribution of cocaine base (aiding and abetting).
Scotland’s counsel filed an Anders brief indicating no meritorious appeal but questioning Rule 11 compliance, voluntariness of the plea, and the reasonableness of a 162‑month sentence.
Scotland consented to a magistrate judge for arraignment and plea; the magistrate conducted a Rule 11 colloquy.
Scotland did not move to withdraw his plea in district court; the Fourth Circuit reviewed any Rule 11 error for plain error.
The Fourth Circuit affirmed the convictions but found reversible error in the written judgment: two non‑mandatory supervised‑release conditions appeared only in the written judgment and were not orally pronounced.
The court vacated the sentence and remanded for resentencing; it did not reach other sentencing challenges because resentencing was required.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequacy of Rule 11 plea colloquy	Magistrate judge complied with Rule 11 and plea was valid	Scotland argued Rule 11 errors rendered plea unknowing/invalid	Plea colloquy was sufficient; no plain error in accepting the plea
Standard of review for unpreserved Rule 11 error	Plain‑error review applies	N/A (defendant did not preserve)	Plain‑error standard applies; defendant must show reasonable probability he would not have pleaded guilty; not met
Validity of supervised‑release conditions in written judgment	Written conditions reflect sentencing court’s intent / enforceable	Scotland argued conditions were non‑mandatory and were not orally pronounced	Two non‑mandatory conditions first appeared only in written judgment; sentence vacated and remanded for resentencing
Reasonableness of 162‑month sentence	Sentence reasonable	Scotland questioned sentence reasonableness	Court did not decide reasonableness on appeal because of required resentencing

Anders v. California, 386 U.S. 738 (1967) (counsel must file brief notifying court of lack of meritorious grounds for appeal)
United States v. Williams, 811 F.3d 621 (4th Cir. 2016) (Rule 11 plea colloquy requirements)
United States v. DeFusco, 949 F.2d 114 (4th Cir. 1991) (standards for voluntariness and factual basis of plea)
United States v. Sanya, 774 F.3d 812 (4th Cir. 2014) (plain‑error review in guilty plea context)
United States v. Lockhart, 947 F.3d 187 (4th Cir.) (en banc) (elements of plain error review)
United States v. Rogers, 961 F.3d 291 (4th Cir.) (review whether written judgment matches oral pronouncement)
United States v. Singletary, 984 F.3d 341 (4th Cir.) (non‑mandatory supervised‑release conditions must be orally pronounced or incorporated on the record)