United States v. Carson, No. 21-3780 (6th Cir. 2022)
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Carson, indicted for engaging in a racketeering conspiracy, 18 U.S.C. 1962(d), and for murder in aid of racketeering, section 1959(a)(1), agreed to plead guilty to racketeering conspiracy in exchange for a 360-month prison term, to run concurrent to Carson's seven-year sentence on a state conviction for aggravated robbery. A magistrate found Carson to be “fully competent” and found his plea to be knowing and voluntary. In February 2020, the district court accepted the plea. Carson filed a pro se motion to withdraw his plea in August 2020, arguing that he entered the plea “before [he] fully understood what [he] was actually saying [he] was guilty of,” and that he thought he would otherwise receive the death penalty. He later claimed ineffective assistance of counsel argument.
The district court appointed new counsel, held an evidentiary hearing; determined Carson was not “operating under a misunderstanding when he entered into his plea,” despite the “muddy” record regarding what exactly counsel told Carson about the amount of actual time to be served; and found that counsel had told Carson that the government was not seeking the death penalty before Carson’s entering the plea. The Sixth Circuit affirmed Carson’s 360-month sentence. The district court acted within its discretion; each of the seven “Goddard” factors weighs against withdrawal. Carson cannot show deficient performance by counsel or prejudice as to his length of incarceration argument.
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