Background
John Ryan Zajac pled guilty without a plea agreement to unlawful possession of a firearm and possession with intent to distribute cocaine. The district court sentenced him to one hundred thirty-five months in prison. On appeal, counsel filed a brief under Anders v. California conceding no meritorious issues while requesting a review of the record for possible errors.
The court’s reasoning
The court reviewed the adequacy of the Rule eleven hearing for plain error and found the magistrate judge committed no error in accepting the guilty plea. The district court properly calculated the Sentencing Guidelines range, afforded the defendant an opportunity to allocute, and explained the sentence. The court also found the special conditions of supervised release consistent with the oral pronouncement. Under an abuse of discretion standard, the sentence was within the Guidelines range and rebuttal of the presumption of reasonableness was not shown.
What it means going forward
The affirmation reinforces the standard of review for plea colloquies and sentencing in the Fourth Circuit when no specific objections are raised by the defendant.