Donald Stenson pleaded guilty to two counts of sex trafficking of a minor in violation of federal law. Following his plea, he moved to withdraw it, arguing that he felt rushed to sign the plea agreement on the morning of the hearing and that his use of the anti-anxiety medication Clonazepam had materially impaired his cognition. The district court held an evidentiary hearing and denied the motion, finding that Stenson's plea was knowing and voluntary. Stenson appealed, contending that the district court abused its discretion by ignoring the impact of his medication and the timing of the plea agreement.
The Seventh Circuit reviewed the denial for abuse of discretion, examining whether the plea was entered knowingly and voluntarily. The court noted that a defendant bears a heavy burden to show a fair and just reason for withdrawal, particularly when they have made contrary admissions during the plea colloquy. Regarding the claim that Stenson felt rushed, the court pointed to the record where Stenson explicitly stated he was 'very satisfied' with his lawyers and had reviewed the agreement. The court reasoned that if Stenson felt pressured, he had the opportunity to say so during the colloquy. On the issue of medication, the court emphasized that the district judge observed Stenson firsthand and found no signs of confusion or distress. Stenson's demeanor and his signed representation that he was not under the influence of any impairing drugs weighed heavily against his claim. The court also rejected reliance on a general internet list of Clonazepam side effects, citing precedent that requires a qualified psychiatrist's affidavit to prove that a specific medication impaired a defendant's ability to think, rather than assuming impairment from the mere fact of taking the drug.
The judgment is affirmed, meaning Stenson's guilty plea stands and he remains subject to sentencing for sex trafficking. The decision reinforces that defendants cannot easily withdraw pleas based on post-hoc claims of medication effects without expert psychiatric evidence, and it underscores the weight given to a trial judge's firsthand observation of a defendant's demeanor during a plea colloquy.
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