The First Circuit ruled on Monday that a Puerto Rican federal court did enough to inform a drug defendant of the nature of his plea bargain before he accepted it, despite his confusion about the specific intent of the crime.
Plea colloquies are often the subject of appeals, but the Court in U.S. v. Ramos-Mejia gives the government a break in just how much a defendant needs to know.
Withdrawing a Plea
As in all criminal plea bargains, a defendant who makes a change in plea must confirm to the court that the plea is:
Here, the appellant Domingo Ramos-Mejia pleaded guilty to conspiracy to possess cocaine with intent to distribute, a charge that he claims he did not understand required the government to prove his “specific intent to effectuate … distributing drugs.”
The First Circuit was pretty snippy in this regard, declaring that it is basic knowledge (look up “abecedarian”) that a defendant lacks an absolute right to withdraw the plea, but continued on the merits of Ramos-Mejia’s claim.
Fun Facts About Pleas
While considering the validity of Ramos-Mejia’s claim of an unintelligent plea, the Court dropped some general knowledge about plea agreements:
- Plea bargain appeal waivers are often incredibly ineffective. After all, if the plea agreement is faulty, the appeal provision is worthless.
- There aren’t magic words to a plea colloquy. Reading the charges and the factual allegations supporting the charge are usually enough.
- More complex cases require more care, but here the charges were simple enough that Ramos-Mejia should have understood what he was pleading.
Ramos-Mejia reviewed the plea agreement with his attorney and agreed to the terms, so without any showing of coercion or good cause, Ramos-Mejia should be held to his words that he had a knowing, intelligent, and voluntary agreement with the charge.
The First Circuit does not allow take-backs whenever it is convenient for the defendant.
Factual Basis Can Be Pretty Light
The Ramos-Mejia Court also opined that the government doesn’t need to establish every element of the charges in the plea in its allegations beyond a reasonable doubt, simply establishing a “rational basis” for guilt is enough.
Rational basis, as federal jurisprudence goes, is a pretty low standard, and with exception to the recent same-sex marriage cases, Article III courts have rarely found government action to fail rational basis review.
This case was no exception, and the court ruled that there was enough of a factual predicate in the plea to connect the dots in finding the appropriate specific intent.
The standard to withdraw a plea is pretty high in run of the mill cases, so courts will be very reluctant to allow defendants a do-over.
- How to Withdraw a Guilty Plea (FindLaw’s Blotter)
- Eighth Circuit Rejects Defendant’s Motion to Withdraw Guilty Plea (FindLaw’s U.S. 8th Circuit Blog)
- Defendant Can’t Withdraw Guilty Plea After Waiving Appeal (FindLaw’s U.S. 7th Circuit Blog)
- Defendant Needs Fair and Just Reason to Withdraw Guilty Plea (FindLaw’s U.S. 8th Circuit Blog)