Withdrawal of Guilty Plea

Listen to this article

7^th Circuit Court of Appeals

Case Name: United States of America v. Bryant D. Aron

Case No.: 22-2364

Officials: Rovner, Wood, and Hamilton, Circuit Judges.

Focus: Withdrawal of Guilty Plea

Aron faced indictment by a grand jury for possessing a firearm and ammunition as a felon, contravening 18 U.S.C. § 922(g)(1). Initially, Aron opted to plead guilty under a binding agreement, proposing a 96-month imprisonment term. However, the district court declined this sentencing recommendation. With the plea deal binding, Aron chose to retract his guilty plea. Rather than pursuing an alternate plea agreement, Aron proceeded to trial, where a jury convicted him, earning the statutory maximum of 120 months’ imprisonment.

The district court’s refusal to accept the plea agreement’s sentencing recommendation prompted Aron’s withdrawal of his guilty plea and trial decision. Following conviction and sentencing, Aron appealed, contesting various aspects of the indictment and the plea/sentencing process. He argued the indictment lacked a crucial element, he had valid reasons for not raising this issue earlier, and the indictment flaw amounted to either structural error or met the plain error standard.

The Seventh Circuit dismissed Aron’s contentions. It deemed the indictment sound and found Aron’s failure to raise the objection timely. Additionally, Aron couldn’t demonstrate valid reasons for not raising the objection pretrial, hence precluding plain error review.

Aron also contested the district court’s dismissal of his binding plea agreement. He claimed the court interfered with the negotiation process, lacked solid grounds for rejecting the agreement, and failed to provide sufficient notice of its rejection. The Court of Appeals rejected these claims, upholding the district court’s decision.

Affirmed.

Decided 04/16/24

Full Text