In United States v. Delvalle, No. 22-1539-cr (2d Cir. Mar. 5, 2024) (per curiam), the Court reiterated its longstanding rule that a guilty plea is not rendered involuntary or unintelligent simply because the defendant expected to receive a lower sentence than he ultimately received.
Delvalle pleaded guilty to a drug conspiracy. The parties estimated that his Guidelines range was 360-480 months, with a statutory minimum term of 60 months. During the plea colloquy, the defendant acknowledged that he had not been “promised” a below-Guidelines sentence, but nevertheless thought it was a “big maybe.” He was disappointed at sentencing when the judge imposed 420 months of imprisonment.
On appeal, he argued that his plea was involuntary because he believed that he would receive a below-Guidelines sentence, and that this belief influenced his decision to plead guilty. The Circuit rejected this argument, “reiterat[ing] the well settled rule that a defendant’s guilty plea is not involuntary simply because he had, at the time of entering his plea, a mistaken expectation that he would receive a lesser sentence than what the district court ultimately imposed.”
There’s nothing new here, so one wonders why the Court felt compelled to publish this opinion. Perhaps it believed a reminder was necessary for the bar as well as defendants considering a guilty plea to a federal crime.
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