United States v. Santiago-Miranda, No. 09-2276 (1st Cir. 2011)Annotate this Case
After pleading guilty to conspiring to possess with intent to distribute significant amounts of cocaine, crack, and marijuana, defendant moved to withdraw his plea as involuntary due to his excessive consumption of prescription drugs, lack of sleep, familial coercion, and history of bipolar disorder. The district court denied the motion and sentenced him to 380 months in prison. The First Circuit affirmed, bypassing an argument that appeal was barred by a plea provision waiving his right to appeal. Defendant's sworn statement were so lacking in detail and corroboration, the district court was justified in relying on the change-of-plea colloquy and signed plea agreement to deny the motion, and in doing so without an evidentiary hearing. The court noted the "suspect" timing of the motion, after receipt of an unfavorable sentencing report.