U.S. v. Goliday

Ct. of Appeals vacated defendant’s guilty plea as to charge of conspiracy to distribute heroin, where record showed during plea proceeding that defendant did not understand how conspiracy offense differed from just buying and selling drugs. Defendant testified that he purchased two ounces of heroin on weekly basis from same supplier during prior year, and record failed to contain any proof of joint criminal purpose beyond mere buyer/seller relationship. Fact that defendant made regular large-quantity purchases of heroin, by itself, was insufficient to establish existence of conspiracy.. Moreover, Dist. Ct. did not ensure that defendant had real notice of true nature of conspiracy charge.