United States v. Roads, No. 23-1828 (8th Cir. 2024)
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Jeffrey Roads was convicted of transporting and accessing child pornography, and received a 324-month prison sentence. He appealed, alleging conflicts of interest among his defense counsel and the presiding judge. The United States Court of Appeals for the Eighth Circuit previously vacated Roads's sentence and ordered a lower court to determine whether a conflict of interest among Roads's defense counsel may have affected his substantial rights. After re-assignment of the case to a different judge and changes in counsel, Roads's motions for disclosure of information and recusal were denied. His motion to withdraw his guilty plea was also denied, and he was re-sentenced to the same term of imprisonment.
On appeal to the Eighth Circuit, Roads argued that the district court erred in denying his motions and in applying a two-level obstruction enhancement during sentencing. He claimed that a reasonable person may question the impartiality of the court due to perceived personal relationships with federal officials or court employees who had been threatened by another individual, Justin Fletcher.
However, the Appeals Court concluded that the district court did not abuse its discretion in denying Roads's motions. It found that Roads had failed to provide any information suggesting the court could not be impartial. The court also found that Roads's reasons for recusal were based on inaccurate "facts" and mere speculation. The court denied Roads's motion to withdraw his guilty plea as he failed to show a fair and just reason for withdrawal. It concluded that the district court was correct in applying the obstruction enhancement, as Roads had attempted to destroy evidence. Therefore, the Eighth Circuit affirmed the judgment of the district court, upholding Roads's sentence.
Court Description: [Erickson, Author, with Benton and Kobes, Circuit Judges] Criminal case - Criminal procedure. The district court did not abuse its discretion in denying defendant's motion to recuse all judges in the district after he had threatened federal officials and court employees, as defendant could not show that the court had a relationship with any of the persons that presented a conflict or basis that would cause a reasonable person to question the court's impartiality. The district court also did not err in denying defendant's motion to withdraw his guilty plea which was based on a conflict of interest his counsel developed after the plea had already been entered. The district court's application of a sentencing enhancement for destroying evidence is affirmed because defendant attempted to destroy evidence and the enhancement applies equally to attempts.
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