UNITED STATES v. SMITH (2021)

United States Court of Appeals, Fourth Circuit.2021-09-14No. No. 20-7656

Summary · law.co

Holding. The court affirmed the district court's order denying Smith's motion to withdraw his guilty plea and denied his attempt to file a successive § 2255 motion because his claims did not meet the required legal standard.

Dalton Laquane Smith sought to withdraw his guilty plea through a postjudgment motion, which the district court rejected. On appeal, Smith presented arguments that the appellate court treated as an attempt to file a second or successive motion under the federal habeas statute rather than a traditional appeal challenging the denial of his withdrawal request.

The court examined Smith's claims against the legal standard required for successive habeas motions and determined they fell short. Because Smith's arguments did not satisfy the applicable requirements, the court declined to permit him to file such a motion. The appellate court found the district court's initial denial of the guilty-plea withdrawal motion was proper.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Standards for withdrawing a guilty plea after judgment
Requirements for filing successive federal habeas motions
Treatment of notices of appeal as applications for successive relief

Procedural posture

Smith appealed the district court's denial of his postjudgment motion to withdraw his guilty plea, and the appellate court construed his appeal as an application for authorization to file a second or successive § 2255 habeas motion.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

Dalton Laquane Smith appeals the district courts order denying his postjudgment motion to withdraw his guilty plea. Our review of the record confirms that the district court properly denied Smiths motion. See Fed. R. Crim. P. 11(e). Accordingly, we affirm the district courts order.

Consistent with our decision in United States v. Winestock, 340 F.3d 200, 208 (4th Cir. 2003), we construe Smiths notice of appeal and informal brief as an application to file a second or successive 28 U.S.C. § 2255 motion. Upon review, we conclude that Smiths claims do not meet the relevant standard. See 28 U.S.C. § 2255(h). We therefore deny authorization to file a successive § 2255 motion. We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process.

AFFIRMED

PER CURIAM:

Affirmed by unpublished per curiam opinion.

Unpublished opinions are not binding precedent in this circuit.