Reported / Citable
Background
Dequail Deshawn Willard appeared with counsel before a U.S. magistrate judge and consented, orally and in writing, to have the magistrate judge conduct his guilty-plea proceeding under Federal Rule of Criminal Procedure 11. Final approval of the plea and sentencing remained with the presiding district judge.
Under a written plea agreement with the government, Willard pleaded guilty to Count Three of the indictment, which charged possession with intent to distribute cocaine base in violation of 21 U.S.C. §§ 841(a)(1) and 841(b)(1)(C). The magistrate judge placed Willard under oath, addressed the subjects required by Rule 11, and confirmed his understanding.
The Court’s Holding
Magistrate Judge Amanda R. Burch found that Willard understood the charge, its essential elements and penalties, the plea agreement and supplement, and the constitutional and statutory rights he was waiving. She also found that Willard was competent, that his plea was knowing and voluntary, and that a factual basis supported it.
The magistrate judge recommended that the district judge accept Willard’s guilty plea, adjudge him guilty, and impose sentence accordingly. The report was not a final adjudication: it expressly recognized the district judge’s final decision-making authority and gave Willard 14 days to object.
Key Takeaways
- Willard pleaded guilty to possession with intent to distribute cocaine base under a written plea agreement.
- The magistrate judge found the plea knowing, voluntary, competent, and supported by a factual basis.
- The recommendation remains subject to the district judge’s review and final approval, with objections due within 14 days.
Why It Matters
The report illustrates the role magistrate judges may perform in felony guilty-plea proceedings when a defendant consents. A magistrate judge may conduct the Rule 11 colloquy and recommend acceptance, while the district judge retains final authority over the plea and sentencing.