United States v. Tyrone Rogers, 678 F. App'x 108

Rogers pleaded guilty to conspiracy to distribute and possess with intent to distribute phencyclidine and cocaine base under 21 U.S.C. §§ 841(a)(1), (b)(1)(C), 846.
He received a below-Guidelines sentence of 108 months imprisonment.
Counsel filed an Anders brief asserting no meritorious issues but questioning plea validity and sentence reasonableness; Rogers did not file a pro se brief.
The Government did not respond to the Anders brief.
The panel reviews for plain error on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Plea colloquy sufficiency	Rogers contends potential plea deficiencies were not adequately reviewed.	Rogers did not oppose the plea as understood in court.	No reversible error; plea reading in open court not required to affect outcome.
Sentencing procedure and prejudice	District court failed to explicitly confirm PSR review by Rogers.	After counsel objected, the court's downward adjustment rendered any error non-prejudicial.	No reversible error; error did not affect sentence; remand unnecessary.

United States v. Lockhart, 58 F.3d 86 (4th Cir. 1995) (plain-error review framework for appellate errors)
United States v. Olano, 507 U.S. 725 (U.S. 1993) (defining plain-error prejudice standard)
United States v. Garrett, 371 F. App’x 429 (4th Cir. 2010) (remand for resentencing when error non-prejudicial)
Anders v. California, 386 U.S. 738 (U.S. 1967) (counsel's duties when no meritorious issues found)