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United States v. Larry Wayne Natt

Citations: 52 F.3d 331; 1995 WL 236004Docket: 94-3471

Court: Court of Appeals for the Eighth Circuit; April 24, 1995; Federal Appellate Court

Narrative Opinion Summary

The case involves an appeal by Larry Wayne Natt from a judgment of the District Court for the Western District of Arkansas, following his guilty plea to drug and weapons charges. Natt contested the denial of his motion to withdraw his plea, arguing it was not made intelligently or voluntarily due to alleged misinformation about his maximum sentence and claims of coercion. Despite his assertions, the district court found no fair and just reason to allow the withdrawal of his plea. At sentencing, Natt further contended that there was an insufficient factual basis for one of the counts, and sought an acceptance-of-responsibility reduction, both of which were denied. The appellate court upheld the lower court's rulings, determining that the plea was informed and voluntary, and that the rejection of the acceptance-of-responsibility reduction was justified given Natt's post-arrest conduct. Consequently, Natt's sentence of 188 months, incorporating both concurrent and consecutive terms with supervised release, was affirmed by the appellate court.

Legal Issues Addressed

Acceptance of Responsibility Reduction

Application: The court concluded that Natt's behavior post-arrest indicated an intent to reduce his sentence rather than a genuine acknowledgment of wrongdoing, thus denying the reduction for acceptance of responsibility.

Reasoning: Although the court noted some indication of Natt's acceptance, it concluded that his post-arrest behavior suggested an intent to reduce his sentencing rather than a genuine acknowledgment of wrongdoing.

Intelligent and Voluntary Plea

Application: The court held that Natt's plea was intelligent and voluntary, as he was adequately informed of the punishment range, and no binding promises outside the plea agreement were made.

Reasoning: Natt failed to prove that he was not adequately advised of the potential supervised release term, as the court had complied with procedural requirements, informing him of the possible punishment range.

Sufficiency of Factual Basis for Plea

Application: Natt's admission during the plea hearing to purchasing drugs and a handgun established a sufficient factual basis for his guilty plea on Count I.

Reasoning: During the plea hearing, he admitted to purchasing five kilograms of cocaine, marijuana, and a handgun for $85,000 and acknowledged his intent to distribute cocaine.

Withdrawal of Guilty Plea

Application: The appellate court affirmed the district court's decision, noting that Natt failed to provide a fair and just reason to withdraw his guilty plea.

Reasoning: The district court held a hearing and denied his motion, concluding he did not provide a fair and just reason to withdraw the plea.