Case Explained: United States of America v. Thomas W. Pitts

Court: United States Court of Appeals for the Eighth Circuit

Filed: 2026-07-17

The eighth-circuit granted appointed counsel’s motion to withdraw under *Anders v. California* and affirmed the defendant’s conviction and sentence of 151 months for a drug conspiracy offense. The court applied the standard of review for guilty pleas, determining that the district court complied with Federal Rule of Criminal Procedure 11 and that the plea was knowing and voluntary. In addressing the claim of plain error regarding the failure to follow Rule 11, the court held that the defendant failed to demonstrate a reasonable probability that he would not have entered the plea absent any alleged error. Additionally, after an independent review of the record pursuant to *Penson v. Ohio*, the court found no nonfrivolous issues supporting an appeal. Consequently, the judgment of the district court is affirmed and counsel is permitted to withdraw from representation.

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