U.S. v. Dyer

Dist. Ct. did not commit plain error in denying defendant’s motions to withdraw his guilty pleas to wire fraud and unlawful financial transactions charges. While defendant argued that instant plea colloquies were inadequate because they did not sufficiently explore potential effects of defendant’s bipolar disorder that could have impacted his decision to enter into guilty pleas, defendant failed to point to any evidence that his judgment was significantly impaired during plea-agreement negotiations or during either plea colloquy. Moreover, defendant testified that he was not under influence of drugs or alcohol and agreed with magistrate’s assessment that he was “fully in the moment and understanding what’s going on.” Ct. further rejected notion that fact that defendant had mental illness was sufficient by itself to establish that said illness obstructed his ability to understand his pleas. Also, fact that magistrate elicited only one-word responses to questions posed during colloquy did not require different result.