Background
Defendant Justin Stiger was involved in a drug conspiracy involving fentanyl and cocaine between Arizona and Memphis, Tennessee. After a jury deadlocked on conspiracy counts, Stiger pleaded guilty to conspiracy to possess with intent to distribute in exchange for a joint recommendation of a sixty-month sentence. He later moved to withdraw the plea, claiming innocence and pressure from counsel. The district court denied the motion, found Stiger in breach of the plea agreement, and sentenced him to one hundred twenty months in prison.
The court’s reasoning
The court found that the district court complied with Federal Rule of Criminal Procedure eleven by ensuring Stiger understood the nature of the charges and the essential elements of conspiracy. The record showed ample evidence of a factual basis for the plea, including communications between Stiger and his co-conspirator and Stiger’s travel to Memphis for drug transactions. The court held that Stiger’s arguments regarding the denial of his motion to withdraw and his sentence were waived because his plea agreement did not preserve the right to appeal the denial of the motion and limited the right to appeal the sentence to cases where the sentence exceeded the statutory maximum or Guidelines range.
What it means going forward
This decision reinforces that defendants who breach plea agreements and fail to preserve specific appeal rights in the agreement will be barred from challenging the denial of motions to withdraw pleas or the resulting sentences on appeal.