Court Again Leaves a Guilty Plea in Place

Once bound to a plea agreement with the Government, it is often difficult for a defendant to find his way out of that agreement. The same holds true for Phillip Watkins. Ninety-eight days after the district court accepted his guilty plea to conspiring to possess and distribute heroin (resulting in injury) and to witness tampering, Mr. Watkins filed a motion to withdraw the same. Finding that the Bashara factors weighed against him, the district court denied his motion.

In a published opinion, the Sixth Circuit affirmed the denial of Mr. Watkins's motion. While the Court found that all of the Bashara factors weighed against allowing Mr. Watkins to withdraw his guilty plea, one holding, in particular, caught this author's eye: his claim that the stresses of solitary confinement while awaiting trial forced him to plead guilty. Although the district court never conducted an evidentiary hearing about these claims, the Court rejected Watkins's argument by relying on his answers to the Rule 11 questions asked by the district court during his rearraignment.

Once accepted, a guilty plea is difficult to withdraw. This case is no exception, even though an evidentiary hearing might have helped to provide more details about Mr. Watkins claims regarding his solitary confinement.