United States v. William Rutzler
664 F. App'x 276
4th Cir.2016Background
- Defendant William Edward Rutzler pled guilty pursuant to a written plea agreement to conspiracy to distribute heroin in violation of federal narcotics statutes.
- The district court accepted the plea and sentenced Rutzler to 84 months’ imprisonment, the bottom of the Guidelines range.
- Appellate counsel filed an Anders brief raising possible defects in the indictment, the voluntariness/validity of the plea, and the propriety of the sentence; Rutzler did not file a pro se brief.
- The Fourth Circuit reviewed whether the indictment was flawed, whether the Rule 11 plea colloquy was adequate, and whether the sentence was procedurally and substantively reasonable.
- The court concluded Rutzler’s guilty plea was knowing and voluntary, nonjurisdictional defects were waived, and the within-Guidelines sentence was presumptively reasonable and not an abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency / defects in the indictment | Rutzler (via counsel) questioned whether the indictment properly alleged the offense | Government maintained the indictment was sufficient; plea waived nonjurisdictional defects | Held: No defect affecting jurisdiction; nonjurisdictional challenges waived by valid guilty plea |
| Validity of guilty plea (Rule 11) | Rutzler suggested plea might not have been knowing/voluntary | Government argued Rule 11 colloquy complied and plea was voluntary | Held: District court complied with Rule 11; plea was knowing and voluntary |
| Standard of review for unpreserved Rule 11 errors | Rutzler contended any Rule 11 error warrants reversal | Government urged plain-error review and that no plain error occurred | Held: Plain-error review applied; no plain error and no effect on substantial rights |
| Sentence reasonableness (procedural & substantive) | Rutzler challenged sentencing procedures and outcome | Government argued sentence was at bottom of Guidelines and reasonable | Held: Minor Rule 32(j) omission was harmless; sentence within Guidelines presumed reasonable and presumption not rebutted |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (U.S. 1967) (procedures for counsel to seek withdrawal when appeal is frivolous)
- United States v. Smith, 640 F.3d 580 (4th Cir. 2011) (guilty plea waives nonjurisdictional pre-plea defects)
- United States v. DeFusco, 949 F.2d 114 (4th Cir. 1991) (Rule 11 plea colloquy requirements)
- United States v. Sanya, 774 F.3d 812 (4th Cir. 2014) (plain-error review for unpreserved Rule 11 claims)
- United States v. Martinovich, 810 F.3d 232 (4th Cir. 2016) (abuse-of-discretion standard for sentence review)
- United States v. Dowell, 771 F.3d 162 (4th Cir. 2014) (procedural-error components in sentencing review)
- Gall v. United States, 552 U.S. 38 (U.S. 2007) (substantive-reasonableness review under totality of circumstances)
- United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (presumption of reasonableness for within-Guidelines sentences)