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United States v. Randolph Baldwin, United States of America v. Cassandra Baldwin
Citations: 60 F.3d 825; 1995 U.S. App. LEXIS 24957Docket: 94-5141
Court: Court of Appeals for the Fourth Circuit; July 6, 1995; Federal Appellate Court
Randolph and Cassandra Baldwin appeal their convictions and sentences for aiding and abetting the maintenance of a place for manufacturing, distributing, or using cocaine base, in violation of 21 U.S.C. § 856(a)(1) and 18 U.S.C. § 2. Their attorneys filed a brief under Anders v. California, indicating no meritorious issues for appeal, and the Baldwins did not submit supplemental briefs. The court notes that the Baldwins' motions to withdraw their guilty pleas were filed after their appeals, leaving the district court without jurisdiction to consider them. The court also addresses the merits of these motions, stating that a guilty plea can only be withdrawn under specific circumstances, such as proving a miscarriage of justice, which the Baldwins failed to demonstrate. The Baldwins claimed their pleas were involuntary due to ineffective assistance of counsel and prosecutorial misconduct. However, the record lacks evidence to support these claims, with the court emphasizing that mere assertions are insufficient for proving ineffective assistance or misconduct. Such claims are better suited for collateral proceedings. After a thorough examination of the record, the court found no potentially meritorious issues and affirmed the district court's judgment, upholding the Baldwins' convictions and sentences. Counsel is required to inform the Baldwins of their right to petition the Supreme Court for further review, and if counsel believes such a petition would be frivolous, they may seek to withdraw from representation. Oral argument was deemed unnecessary as the case's facts and legal arguments were adequately presented in the written materials.