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United States v. Blattner

Citations: 195 F. Supp. 3d 1205; 2016 U.S. Dist. LEXIS 114225; 2016 WL 4491509Docket: No. CR 13-0328 JB

Court: District Court, D. New Mexico; July 19, 2016; Federal District Court

Narrative Opinion Summary

The case involves Defendant Chris Blattner's motion to withdraw his guilty plea, which he entered on April 10, 2015, for charges related to drug trafficking and firearm possession. Blattner filed the motion nearly seven months later, claiming he was under the influence of LSD during the plea hearing, which impaired his ability to enter a knowing and voluntary plea. The court assessed factors including the assertion of innocence, potential prejudice to the government, and the delay in filing the motion. It found no credible evidence supporting Blattner's claim of impairment, noting the lack of observable symptoms of LSD use during the hearing and his consistent, lucid engagement throughout the proceedings. The court also emphasized the strong presumption of truthfulness attached to his sworn statements during the plea colloquy. Additionally, the court considered the prejudice to the government due to the time elapsed since the offenses, which could affect witness availability and the integrity of evidence. Ultimately, the court denied Blattner's motion, concluding he had not demonstrated a fair and just reason for withdrawing his plea, and affirmed that his plea was knowing and voluntary, supported by competent legal counsel.

Legal Issues Addressed

Burden of Proof in Motion to Withdraw Guilty Pleas

Application: Blattner bore the burden of proving a fair and just reason for withdrawal, which he failed to do, as the court found insufficient evidence of LSD influence during the plea hearing.

Reasoning: Blattner bears the burden of proof to show he was under LSD's influence, but the court finds he lacks sufficient evidence to meet this burden.

Importance of Knowing and Voluntary Guilty Pleas

Application: The court emphasized the necessity for a plea to be entered knowingly and voluntarily, determining that Blattner's plea met these criteria despite his subsequent claims of impairment.

Reasoning: The court, Mr. Kochersberger, and the United States confirmed that his admissions met the elements of the offenses charged.

Influence of Drug Use on Plea Validity

Application: Blattner claimed LSD use impaired his ability to voluntarily and knowingly enter a guilty plea, but the court found no credible evidence supporting his claim, undermining his motion to withdraw the plea.

Reasoning: Blattner argues that his guilty plea was invalid due to not being made knowingly and voluntarily, stating that the plea must reflect a voluntary and intelligent choice among available options.

Prejudice to the Government in Withdrawal of Guilty Pleas

Application: The potential prejudice to the government due to witness availability and the three-year gap since the offense was a factor against allowing withdrawal of Blattner's plea.

Reasoning: The government faces challenges in recalling approximately twenty-four witnesses, some of whom may have relocated or retired, complicating trial preparation.

Role of Defense Counsel in Plea Validity

Application: The court determined that Blattner had competent legal representation, and his attorney's actions during the plea process did not indicate any deficiencies that would invalidate the plea.

Reasoning: Blattner confirmed to Chief Magistrate Judge Molzen that he had sufficient time to consult with his attorney, Mr. Kochersberger, and was satisfied with his representation.

Withdrawal of Guilty Pleas under Federal Rule of Criminal Procedure 11(d)(2)(B)

Application: The court evaluated whether Chris Blattner provided a fair and just reason for withdrawing his guilty plea, ultimately concluding that he failed to meet the burden of proof necessary to warrant withdrawal.

Reasoning: Blattner filed a Motion to withdraw his guilty plea nearly seven months after its acceptance, without providing a reason for the delay.