United States v. House

Defendants House and Van Pelt appealed their sentences imposed after pleading guilty to numerous counts related to their participation in a large scale methamphetamine distribution scheme. The Eighth Circuit affirmed defendants' sentences, holding that the district court did not plainly err by conducting a 21 U.S.C. 851(b) inquiry. In this case, defendants failed to show that there was a reasonable probability that their sentences would be different if the district court had engaged in the section 851(b) colloquy. Nor did they show that their prior conviction was invalid or that their rights were otherwise affected.The court also held that House failed to show that any of the three purported Rule 11 errors affected his decision to plead guilty, and thus failed to satisfy the third prong of the plain error standard. Finally, the district court did not err by calculating the drug quantity attributable to Van Pelt, and by applying a leadership role enhancement to his sentence under USSG 3B1.1(c). View "United States v. House" on Justia Law