U.S. v. White

Dist. Ct. did not err in denying defendant's motion to withdraw his guilty plea after defendant and govt. had discovered that defendant's criminal history made him ineligible for safety-valve reduction, which, in turn negated practical effect of two other reductions govt. had agreed to support. Instant mistake was not about essential term of plea agreement, which did not promise specific sentence, and which contained nonbinding recommendation that premised two-level reduction on defendant's qualification for safety valve treatment. Moreover, defendant's plea colloquy demonstrated that he was aware of consequences of his plea should he not qualify for safety valve treatment.