United States v. Youngs
687 F.3d 56
| 2d Cir. | 2012Background
- Youngs pleaded guilty to two counts of producing and possessing child pornography under a plea agreement.
- Plea hearing included detailed Rule 11 colloquy describing sentences, supervised release, forfeiture, and Sex Offender Registration obligations.
- Act permits civil commitment of a sexually dangerous person at end of incarceration, with a hearing and standard of clear and convincing evidence.
- Civil commitment is not guaranteed; it would require certification and proof at a future time.
- District court’s acceptance of the guilty plea did not inform Youngs of civil commitment risks because those risks are not direct consequences of a guilty plea.
- Court affirmatively concluded the plea was knowing and voluntary.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether civil commitment under the Adam Walsh Act is a direct consequence of a guilty plea. | Youngs argues he should have been advised of civil commitment. | Youngs contends the district court failed to inform him of a direct consequence. | No; civil commitment is collateral, not a direct consequence. |
| Whether Padilla requires disclosure of civil commitment risks in guilty-plea proceedings. | Youngs invokes Padilla to expand due-process duties. | Padilla concerns deportation and Sixth Amendment counsel; not applicable to Rule 11/fifth amendment:** | Padilla does not render civil commitment disclosure mandatory under Rule 11 or due process in this context. |
Key Cases Cited
- Wilson v. McGinnis, 413 F.3d 196 (2d Cir. 2005) (due process standard for knowing and voluntary guilty plea)
- Brady v. United States, 397 U.S. 742 ((1969)) (direct consequences for guilty pleas; collateral consequences need not be explained)
- Boykin v. Alabama, 395 U.S. 238 ((1969)) (requirement of intelligent and voluntary plea)
- McCarthy v. United States, 394 U.S. 459 ((1969)) (Rule 11 purpose and plea allocution guidance)
- Zhang v. United States, 506 F.3d 162 (2d Cir. 2007) (Rule 11 adequacy standards; voluntary/informed plea)
- U.S. v. Vonn, 535 U.S. 55 ((2002)) (plain error review for Rule 11 violations)
- U.S. v. Flaharty, 295 F.3d 182 (2d Cir. 2002) (plain-error standard in Rule 11 context)
- U.S. v. Pipola, 83 F.3d 556 (2d Cir. 1996) (definition of plain error and requirement of prejudice)
- U.S. v. Salerno, 66 F.3d 544 (2d Cir. 1995) (collateral consequences need not be explained; direct consequences matter for plea validity)
- U.S. Currency in the Amount of $228,536.00, 895 F.2d 908 (2d Cir. 1990) (civil penalties not a direct consequence of a guilty plea)
- Padilla v. Kentucky, 130 S. Ct. 1473 (2010) ( Sixth Amendment counsel; deportation context; direct/collateral distinction questioned)
