Decided: January 28, 2016
In a case concerning plea agreements to drug crimes, the Fourth Circuit held that the district court did not plainly err in convicting the defendants. The Fourth Circuit also held that it did not have jurisdiction to review the sentence of one of the defendants. On this basis, the Fourth Circuit affirmed the district court’s conviction of the defendants, and dismissed one defendant’s appeal of her sentence.
David James Williams, III, and Kristin Deantanetta Williams each pled guilty to one count of conspiracy to possess and distribute cocaine and cocaine base, and, under Fed. R. Crim. P. 11(c)(1)(C), stipulated to a sentence of 120 months imprisonment. The district court sentenced each defendant to 120 months imprisonment. Under Anders v. California, both defendants appealed challenging whether their convictions complied with Fed. R. Crim. P. 11. In addition, Kristin challenged the reasonableness of her sentence.
The Fourth Circuit first found that there was no plain error in the defendants’ convictions. The district court complied with Fed. R. Crim. P. 11’s requirement that the trial court speak with the defendant to be sure that he understands the nature of the charge, the mandatory minimum and maximum possible sentences, and the rights relinquished by pleading guilty. The district court also, as required by Fed. R. Crim. P. 11, made sure there was a factual basis for the plea, and that the plea was voluntary.
The Fourth Circuit next found that it did not have jurisdiction to review Kristin’s challenge to her sentence. The Court found that it could only review the sentence if it was “‘imposed in violation of law,’” or “‘as a result of an incorrect application of the [United States] [S]entencing [G]uidelines . . . .’” The Court held that the sentence imposed did not violate the law because 120 months was the mandatory minimum sentence for the crime of which Kristin was convicted. The Court then noted, based on case precedent, that sentences under Rule 11 (c)(1)(C) are generally not thought to be an incorrect application of United States Sentencing Guidelines, because the sentences come from the parties’ agreement, not the Court’s application of the Guidelines. The Court noted an exception to that general rule where the parties’ “‘agreement expressly uses a Guidelines sentencing range applicable to the charged offense to establish the term of imprisonment.’” The exception did not apply in the instant case, however, because Kristin’s plea agreement did not expressly rely upon the Guidelines. On this basis, the Fourth Circuit affirmed the district court’s conviction of the defendants, and dismissed Kristin’s challenge to her sentence.
Katherine H. Flynn