Williams v. U.S.
Dist. Ct. did not err in denying without evidentiary hearing defendant’s habeas petition challenging his 18-year sentence imposed after defendant pleaded guilty to one of three counts of brandishing firearm in furtherance of three underlying robberies, as well as to all three of underlying robberies. At time of plea negotiation, defendant was facing statutory minimum 57-year sentence on firearm charges plus whatever sentence defendant would receive on underlying robberies, and record showed that prosecutor, in accordance with standing Dist. Ct. procedure, emailed Dist. Ct. with proposed offer of 18-year sentence in exchange for instant guilty pleas, and Dist. Ct. responded while negotiations were taking place that defendant would be “fool” not to refuse instant plea agreement. While Dist. Ct.’s response constituted violation of Rule 11(c)(1)’s prohibition on judicial participation in plea negotiations, instant violation did not merit any habeas relief as violation of defendant’s due process rights, since defendant failed to show reasonable probability that but for Dist. Ct.’s email, he would have declined plea agreement with its accompanying sentence. This is so, Ct. of Appeals found, because even though defendant was aware of Dist. Ct.'s email, govt. case against defendant with respect to all charged offenses was particularly strong, and defendant faced at least 57-year minimum sentence on firearms charges alone. Defendant also failed to establish his related ineffective assistance of counsel claim arising out of trial counsel’s failure to raise Rule 11(c)(1) issue since defendant failed to establish any prejudice arising out of said failure.