United States v. Augustus Light, No. 22-3367 (8th Cir. 2022)
Annotate this CaseCourt Description: [Per Curiam - Before Kelly, Stras, and Kobes, Circuit Judges] Criminal case - Sentencing. The district court did not abuse its discretion in denying defendant's motion to withdraw his guilty plea. [ December 20, 2022 ]
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United States Court of Appeals For the Eighth Circuit ___________________________ No. 22-3367 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Augustus Quintrell Light, also known as Stow lllllllllllllllllllllDefendant - Appellant ___________________________ No. 22-3369 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Augustus Quintrell Light, also known as Stow lllllllllllllllllllllDefendant - Appellant ____________ Appeals from United States District Court for the District of Minnesota ____________ Submitted: December 13, 2022 Filed: December 22, 2022 [Unpublished] ____________ Before KELLY, STRAS, and KOBES, Circuit Judges. ____________ PER CURIAM. Augustus Light originally received a 120-month prison sentence for possession with intent to distribute methamphetamine and another 18 months for violating the conditions of supervised release. See 21 U.S.C. § 841(a)(1), (b)(1)(A); see also 18 U.S.C. § 3583(e)(3). We remanded because the 18-month revocation sentence exceeded the statutory maximum. See United States v. Light, No. 212659/2677, 2022 WL 1252227, at *1 (8th Cir. Apr. 28, 2022) (unpublished per curiam). The district court 1 then sentenced him to seven months in prison, two months below the maximum available sentence. In a pro se appeal, Light argues that he should have been able to withdraw his guilty plea. We conclude that the district court did not abuse its discretion in concluding otherwise. See United States v. Cruz, 643 F.3d 639, 641 (8th Cir. 2011). The government fulfilled its obligations under the plea agreement, which did not mandate an illegal sentence. See United States v. Greatwalker, 285 F.3d 727, 729–30 (8th Cir. 2002) (noting that defendants are not entitled to withdraw guilty pleas when a legal sentence “can be reconciled with the plea agreement”). And even assuming that a challenge to the performance of standby counsel could be viable, it must await collateral review. See United States v. Adkins, 636 F.3d 432, 434 (8th Cir. 2011). We accordingly affirm the judgment of the district court. ______________________________ 1 The Honorable Paul A. Magnuson, United States District Judge for the District of Minnesota. -2-
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