United States v. Overton, No. 21-76 (2d Cir. 2022)
Annotate this CaseThe Second Circuit affirmed defendant's conviction for conspiracy to commit sex trafficking of a minor. The court held that acceptance of a guilty plea must be reviewed de novo. The court also concluded that although the district court's use of the term "provisional" was imprecise, the totality of the record reflects that the district court did accept defendant's guilty plea prior to his motion to withdraw that plea. Therefore, the district court correctly applied the Federal Rule of Criminal Procedure 11(d)(2) standard in considering defendant's motion to withdraw his plea after determining that he had not established a Brady violation, and the district court committed no error in denying the motion to withdraw. Finally, the court concluded that defendant's ineffective assistance claim, based on counsel's failure to adequately address the issues that defendant now raises, fails for lack of prejudice.
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