United States v. William Battle, 21-1432

Battle was indicted on multiple counts related to a heroin and sex‑trafficking operation and pleaded guilty to one count of conspiracy to commit sex trafficking (18 U.S.C. § 1594(c)) in exchange for dismissal of other charges.
Defense counsel informed the court that Battle was illiterate and had "some educational and mental challenges," but affirmed Battle was competent to plead.
The District Court conducted an extensive plea colloquy; Battle repeatedly affirmed he understood the charge, rights he waived, the plea agreement, and that the court could impose a sentence up to life.
After the presentence report, Battle submitted a letter (ghostwritten by a cellmate) claiming he misunderstood the plea and had been told a much lower Guidelines range; counsel then expressed belated doubts about Battle’s comprehension.
The District Court construed the letter as a motion to withdraw the plea, held a hearing, credited Battle’s plea colloquy responses and counsel’s prior assurances, denied withdrawal, and sentenced Battle to 210 months (bottom of Guidelines).
On appeal Battle argued (1) the court erred by not ordering a competency hearing and (2) counsel had an actual conflict of interest that denied effective assistance; the Third Circuit affirmed.

Issue	Battle's Argument	Government's Argument	Held
Whether the district court should have ordered a competency hearing under 18 U.S.C. § 4241	Battle: his illiteracy, mental challenges, and post‑plea letter (and counsel’s later qualms) gave reasonable cause to doubt competency	Court/Gov: plea colloquy, counsel’s repeated prior assurances, and Battle’s courtroom responses showed competence; the letter and counsel’s belated doubts were insufficient	No error — no reasonable cause to order competency hearing; court did not abuse discretion
Whether counsel had an actual conflict of interest at the motion hearing (ineffective assistance)	Battle: counsel’s post‑letter hesitation and alleged promise about a low Guidelines range show a conflict affecting representation	Court/Gov: record contains no clear evidence of an actual conflict; alleged promise appears only in a cellmate’s letter that Battle could not recall; plea colloquy contradicts alleged promise	Not cognizable on direct appeal absent clear record showing an actual conflict; no such record here, claim not reached on merits

United States v. Gillette, 738 F.3d 63 (3d Cir. 2013) (reasonable‑cause standard for competency hearings under § 4241)
United States v. Jones, 336 F.3d 245 (3d Cir. 2003) (standard of review for competency and factual findings)
United States v. Leggett, 162 F.3d 237 (3d Cir. 1998) (two‑part competency inquiry: assist counsel and understand proceedings)
Pate v. Robinson, 383 U.S. 375 (1966) (due process requires competency determination when reasonable doubt exists)
United States v. Khattak, 273 F.3d 557 (3d Cir. 2001) (competency and ineffective‑assistance principles)
United States v. Shedrick, 493 F.3d 292 (3d Cir. 2007) (competency review and procedures)
United States v. Malmstrom, 967 F.3d 1 (1st Cir. 2020) (lawyer’s vague acknowledgment of client mental‑health issues alone does not create reasonable cause)
United States v. Siddons, 660 F.3d 699 (3d Cir. 2011) (review of denial of motion to withdraw plea)
United States v. Wilson, 429 F.3d 455 (3d Cir. 2005) (standard for plea withdrawal and appellate review)
United States v. Morena, 547 F.3d 191 (3d Cir. 2008) (actual conflict claims rarely cognizable on direct appeal; require clear record)
United States v. Parr, 22 F.3d 304 (3d Cir. 1994) (conflict must be actual, not hypothetical, to sustain ineffective‑assistance claim)