United States v. Sharp, No. 16-4008 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of defendant's motion to withdraw his guilty plea for drug-related offenses. The court held that the district court did not abuse its discretion in denying the motion to withdraw because defendant failed to show that his counsel's advice was linked to an actual conflict of interest; defense counsel's advice concerning willful blindness was not deficient and did not prejudice defendant; the guilty plea rested on an adequate factual basis; and, because the evidence elicited at sentencing neither rehabilitated defendant's credibility nor undermined the evidence of his guilt, the district court did not plainly err in failing to reconsider the motion to withdraw the guilty plea sua sponte.
Court Description: Gruender, Author, with Smith, Chief Judge, and Wollman, Circuit Judge] Criminal case - Criminal law. The district court did not abuse its discretion by denying defendant's motion to withdraw his guilty plea to charges that he conspired to manufacture and distribute a controlled substance and possessed controlled substances with intent to distribute; claims that his attorney had a conflict of interest because he was a vital witness as to defendant's mens rea rejected as defendant had failed to show that counsel's advice to plead guilty was linked to the conflict; claim that counsel rendered ineffective assistance by misinforming defendant about willful blindness rejected as counsel reasonably believed the government could show that defendant had actual knowledge that the substance he was distributing was a controlled substance; further, there was a factual basis for the plea; the evidence elicited at sentencing neither rehabilitated defendant's credibility not undermined the evidence of his guilt, and the district court did not err in failing to sua sponte reconsider the motion to withdraw the plea.
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