Jerron Williams was charged with assaulting a federal postal worker and using a firearm during the crime. He entered into a plea agreement, pleading guilty to assault under 18 U.S.C. § 111 and using a firearm during a crime of violence under 18 U.S.C. § 924(c). As part of the deal, Williams waived his right to appeal his conviction and sentence. During the change of plea hearing, the magistrate judge explained the charges, and Williams and his attorney confirmed they understood the elements. Later, Williams moved to withdraw his plea, claiming ineffective assistance of counsel, but the district court denied the motion and sentenced him to 153 months. On appeal, Williams raised a new argument for the first time: that § 111(b) is not a 'crime of violence' and therefore could not support his § 924(c) conviction, making his plea invalid under Rule 11 and the Due Process Clause.
The Seventh Circuit, writing for the panel, dismissed the appeal based on two primary grounds: waiver and the adequacy of the plea colloquy. First, the court emphasized that Williams had repeatedly waived the specific argument he now raises. He waived it by pleading guilty, by signing a written waiver of appeal rights, and by failing to raise the issue in his motion to withdraw the plea. The court noted that an unconditional guilty plea waives the right to contest the proper interpretation of the statute of conviction. Second, the court found that the magistrate judge fulfilled all requirements under Federal Rule of Criminal Procedure 11. The judge accurately recounted the essential elements of the charges, and Williams confirmed his understanding. The court clarified that a judge is not required to conjure new legal theories or advise a defendant of potential statutory defenses that the defendant has not raised. Even if there were a dispute over whether § 111(b) qualifies as a crime of violence, the court held that the plea was valid because the defendant understood the nature of the charges and the factual basis for them. The court declined to decide the statutory question of whether § 111(b) is a crime of violence, stating that because Williams waived the argument, the court need not resolve the legal uncertainty.
The dismissal affirms the district court's judgment and sentence. The decision reinforces the binding nature of appeal waivers in plea agreements, even when a defendant later discovers a potential legal flaw in the statutory classification of the predicate offense. It clarifies that defendants cannot raise statutory interpretation challenges on appeal if they have waived the right to appeal and were aware of the general legal landscape at the time of the plea. The underlying legal question of whether § 111(b) qualifies as a crime of violence under § 924(c) remains unresolved by the Seventh Circuit in this case.
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