Curtis Dewayne Miller v. United States

Petitioner Curtis Dewayne Miller pleaded guilty after a jury could not decide whether he was guilty or not in an initial trial and the Government continued to pursue charges at a second trial. Throughout district court proceedings, Miller’s counsel encouraged Miller to plead guilty and warned him that the district court and Government had it out for him. This pressure led Miller to plead guilty after the first day of his second trial. When Miller tried to rescind his plea, the district court erroneously denied his motion and proceeded to impose a 320-month sentence. In addition to erroneously denying Miller’s motion, the decision to put Miller behind bars for the next twenty-six years was based on an error in determining Miller’s offense level. When Miller moved to withdraw his guilty plea, the district court interpreted the Bashara factors in a way that made it impossible for Miller—or any defendant—to withdraw his plea. The district court hardly considered circumstances leading to the plea and leaned on general conclusions about other factors that mischaracterized Miller’s experience, allowed for easy denial of Miller’s motion and prevented Miller from presenting his innocence to a jury.