United States v. Williams, No. 18-4072 (6th Cir. 2019)
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Williams and another man armed with a rifle forced the occupants out of a vehicle. Williams fled to another vehicle driven by a getaway driver; his accomplice drove off in the victims' vehicle. Later that morning, Williams and a juvenile carrying an AR-15 entered a credit union and yelled that it was a robbery. When a security guard drew his weapon, the two fled. Police arrested them after a chase; Hill, their driver, was also arrested. Williams and Hill were charged with the attempted armed robbery of a credit union and with brandishing a firearm during and in relation to that attempted armed robbery. Williams was also charged with carjacking and brandishing a firearm during and in relation to that carjacking. Williams pleaded guilty to all four counts and was sentenced to 205 months' imprisonment.
The Seventh Circuit affirmed, rejecting Williams’s arguments that the district court violated Federal Rule 11 because the plea colloquy failed to advise him as to the accomplice element of the crime and failed to provide a factual basis for the dangerous weapon element. Because aiding and abetting is a theory of liability embodied in every federal indictment, whether specifically charged or not, the court was not required to advise Williams about accomplice liability. The prosecutor, at the court’s direction, read the elements for attempted armed credit union robbery, which were also set out in the plea agreement. Williams affirmed that these elements matched his behavior. The court confirmed that Williams had read the plea agreement and discussed it with counsel. The court directed the prosecutor to summarize the factual basis for Williams’s guilty pleas. Williams agreed that this summary accurately reflected his behavior; the summary provided a sufficient factual basis for the dangerous-weapon element of attempted armed credit union robbery.
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