United States v. Gonzalez-Negron, No. 17-1302 (1st Cir. 2018)
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The First Circuit affirmed Defendant’s conviction for possessing a firearm in furtherance of a drug trafficking crime, holding that Defendant’s argument that the conviction was invalid owing to the district court’s acceptance of Defendant’s guilty plea despite the court’s failure to satisfy Fed. R. Crim. P. 11 failed.
Specifically, the First Circuit held (1) the facts on record are at least arguably sufficient to satisfy the requirement of demonstrating on the record a factual basis for the “in furtherance” element as required under Rule 11; and (2) the court addressed Defendant with enough care to determine that he understood the nature of the “in furtherance” charge to which he was pleading guilty.
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