United States v. Alex Lenard McCoy

Summary

The Fourth Circuit held that a valid appellate waiver does not bar a challenge to the factual basis of a guilty plea, because such a claim goes to the voluntariness of the plea. However, the court found the factual basis sufficient where the defendant stipulated to being a member of a crack-cocaine conspiracy, as a stipulated recitation of facts alone satisfies Rule 11. The defendant's waiver was knowing and voluntary, so his remaining sentencing challenges were dismissed.

Holdings

1. Even valid appeal waivers do not bar claims that a factual basis is insufficient to support a guilty plea.
2. A stipulated recitation of facts alone is sufficient to support a plea, and here the factual basis established the elements of the offense.
3. Because McCoy validly waived his right to appeal the sentence, the court does not consider these issues.

Questions Presented

1. Whether a challenge to the factual basis of a guilty plea falls outside the scope of a valid appellate waiver.
2. Whether the district court erred in finding a sufficient factual basis to support McCoy's guilty plea.
3. Whether the district court erred in its application of the Sentencing Guidelines.

Disposition

dismissed in part and affirmed