United States v. Martin, No. 12-3316 (8th Cir. 2013)
Annotate this CaseDefendant pleaded guilty to five counts of a federal indictment charging him with distributing crack cocaine, being a felon in possession of a firearm, and carrying a firearm during and in relation to a drug trafficking crime. On appeal, defendant contended that the district court's failure to inform him of the 15-year statutory minimum on count IV at his change of plea hearing amounted to a violation of due process and Federal Rule of Criminal Procedure 11. The court concluded that even assuming such error was plain, the error did not affect defendant's substantial rights where defendant's sentence would remain the same at 20 years even without the 15-year term on count IV. Because defendant failed to make the requisite showing that but for the Rule 11 violation, he would have pleaded guilty, the court concluded that the district court did not commit plain error. Finally, the record provided no support for defendant's claim of ineffective assistance of counsel. Accordingly, the court affirmed the judgment.
Court Description: Criminal case - Criminal law. While the court erred by failing to notify defendant of the fifteen-year statutory maximum on his felon in possession of a firearm charge, the error did not affect his substantial rights as his sentence would remain at 20 years even without the fifteen- year term on this count; defendant failed to make a showing that he would not have pleaded guilty if he had been properly informed; while there was no basis in the record here for a claim of ineffective assistance of counsel, the issue should be raised in a Section 2255 proceeding because such claims require development of facts outside the original record.
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