US v. King, No. 19-4865 (4th Cir. 2024)Annotate this Case
In South Carolina, the defendant Darrius Andrez King pleaded guilty to possessing a firearm as a felon after firing a handgun in the air outside a crowded nightclub. During the plea colloquy, the district court did not inform King about the significance of supervised release—that if he violated it, he could face additional prison time exceeding the statutory maximum period for the underlying offense. The United States Court of Appeals for the Fourth Circuit ruled that the Federal Rule of Criminal Procedure 11 does require the district court to inform defendants who intend to plead guilty about the effect of supervised release. However, the court decided not to vacate King’s plea, concluding that the omission did not affect his substantial rights. The court reasoned that there was no indication that King would have tried to withdraw his plea if he had been correctly informed about the potential consequences of violating supervised release, especially given the strength of the case against him. The court therefore affirmed the judgment of the district court.