United States v. Armendariz Soto, No. 10-3307 (10th Cir. 2011)Annotate this Case
The issue before the Tenth Circuit in this appeal was whether a district court must allow a criminal defendant to withdraw his guilty plea when the request was based on a lie. "Unsuprisingly," the Tenth Circuit held that the "law does not permit anyone to compel judicial action based on intentionally false statements." Defendant Cesar Osbaldo Armendariz Soto faced an indictment for his involvement in a drug trafficking conspiracy. As part of an effort to show his cooperation and reduce his sentence, and in consultation with his attorney, Defendant initially agreed to plead guilty to these charges without a plea agreement. Months later (though still before his sentencing hearing), he tried to reverse course, asking the court to allow him to withdraw the plea he had entered and the court had accepted. Defendant argued that his plea wasn't entered knowingly or voluntarily because it was premised on a misunderstanding of the facts. Ultimately the district court refused to allow Defendant to retract his plea, finding "I simply think he is not telling us the truth." Upon review, the Tenth Circuit affirmed the district court's decision: "we are no less at a loss to see how we might say the choice this district judge made was an irrational one."