United States v. Farmer, No. 19-1603 (1st Cir. 2021)
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The First Circuit affirmed Defendant's conviction and sentence imposed after he pled guilty to six counts stemming from a robbery of a federal confidential informant during a guns-for-cash deal, holding that Defendant was not entitled to relief on his allegations of error.
Specifically, the First Circuit held (1) Defendant's challenge based on Rehaif v. United States, 139 S. Ct. 2191 (2019), to his conviction for possession of a firearm by a felon, in violation of 18 U.S.C. 922(g), was without merit; (2) Defendant's challenge to the plea colloquy failed; (3) Defendant's challenge based upon United States v. Davis, 139 S. Ct. 2319 (2019), to the acceptance of his plea to aiding and abetting the use of a firearm during and in relation to a crime of violence, in violation of 18 U.S.C. 2, 924(c), failed on plain error review; (4) the prosecutor did not breach plea agreement; and (5) Defendant's sentence of 198 months' imprisonment was neither procedurally nor substantively unreasonable.
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