United States v. Adebowale Ojo

CourtCourt of Appeals for the Fourth Circuit
DecidedJune 20, 2023
Docket22-4529
StatusUnpublished

This text of United States v. Adebowale Ojo (United States v. Adebowale Ojo) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Adebowale Ojo, (4th Cir. 2023).

Opinion

USCA4 Appeal: 22-4529 Doc: 47 Filed: 06/20/2023 Pg: 1 of 7

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 22-4529

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

ADEBOWALE OJO, a/k/a Debo,

Defendant - Appellant.

Appeal from the United States District Court for the District of Maryland, at Greenbelt. George Jarrod Hazel, District Judge. (8:21-cr-00028-GJH-1)

Submitted: June 12, 2023 Decided: June 20, 2023

Before WYNN and HEYTENS, Circuit Judges, and FLOYD, Senior Circuit Judge.

Affirmed in part, dismissed in part, vacated in part, and remanded by unpublished per curiam opinion.

ON BRIEF: Stuart A. Berman, LERCH, EARLY & BREWER, CHTD., Bethesda, Maryland, for Appellant. Jessica Caroline Collins, Kelly O. Hayes, OFFICE OF THE UNITED STATES ATTORNEY, Greenbelt, Maryland, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 22-4529 Doc: 47 Filed: 06/20/2023 Pg: 2 of 7

PER CURIAM:

Adebowale Oloyede Ojo pleaded guilty pursuant to a written plea agreement to

conspiracy to distribute controlled substances, in violation of 21 U.S.C. §§ 841(b)(1)(B),

846, and distribution of and possession with intent to distribute controlled substances, in

violation of 21 U.S.C. § 841(a)(1), (b)(1)(C). In the plea agreement, Ojo agreed that he

was a Sentencing Guidelines career offender and under Fed. R. Crim. P. 11(c)(1)(C), a

sentence of not less than 132 months nor more than 240 months was appropriate. The

district court sentenced Ojo to 162 months’ imprisonment and four years’ supervised

release. Ojo’s counsel has filed a brief pursuant to Anders v. California, 386 U.S. 738

(1967), stating that there are no meritorious grounds for appeal but raising for the court’s

consideration whether the district court erred by denying Ojo’s motion to withdraw his

guilty plea. Ojo has filed a pro se brief raising the same issue and adds that the factual

basis offered by the Government at his guilty plea hearing did not support the conspiracy

conviction. The Government moves to dismiss the appeal based on the appeal waiver in

the plea agreement.

We begin with the district court’s decision to grant Ojo’s motion to proceed without

counsel during the trial. The Sixth Amendment guarantees not only the right to be

represented by counsel but also the right to self-representation. Faretta v. California, 422

U.S. 806, 819 (1975). “A defendant may waive the right to counsel and proceed at trial

pro se only if the waiver is (1) clear and unequivocal, (2) knowing, intelligent, and

voluntary, and (3) timely.” United States v. Ziegler, 1 F.4th 219, 226 (4th Cir. 2021)

(internal quotation marks omitted). “To waive counsel, a defendant must also be mentally

2 USCA4 Appeal: 22-4529 Doc: 47 Filed: 06/20/2023 Pg: 3 of 7

competent.” Id. “[A] defendant is competent to waive his right to counsel when he (1) has

sufficient present ability to consult with his lawyer with a reasonable degree of rational

understanding, and (2) he has a rational as well as factual understanding of the proceedings

against him.” Id. at 227 (internal quotation marks omitted). “All that is required is the

competence to waive the right to counsel—not the competence to effectively represent

oneself.” Id.

“Whether a defendant waived his right to counsel is a legal question we review de

novo. But we review a district court’s factual competency findings only for clear error.

The determination of whether there has been an intelligent waiver of the right to counsel

must depend, in each case, upon the particular facts and circumstances surrounding that

case, including the background, experience, and conduct of the accused.” Id. (citations and

internal quotation marks omitted). The district court must make the defendant “‘aware of

the dangers and disadvantages of self-representation, so that the record will establish that

he knows what he is doing and his choice is made with eyes open.’” United States v. Bush,

404 F.3d 263, 270 (4th Cir. 2005) (quoting Faretta, 422 U.S. at 835). We do not require

“[a] precise procedure or litany for this evaluation.” United States v. Singleton, 107 F.3d

1091, 1097 (4th Cir. 1997). Because of Ojo’s educational background, his familiarity with

some of the rules and procedures, and the advice given to him about the difficulty in having

access to discovery, we conclude that Ojo was competent to waive counsel and his waiver

was knowing and voluntary.

Next, it was after eight days of trial that Ojo agreed to plead guilty to two of the

charges. Based on the appeal waiver in the plea agreement, the Government moves to

3 USCA4 Appeal: 22-4529 Doc: 47 Filed: 06/20/2023 Pg: 4 of 7

dismiss the appeal. We review the validity of an appeal waiver de novo to “determine

whether [the defendant] knowingly and voluntarily waived his right to appeal.” United

States v. McCoy, 895 F.3d 358, 362 (4th Cir. 2018). Generally, if the district court fully

questions a defendant regarding the waiver of his right to appeal during a plea colloquy

that complies with Fed. R. Crim. P. 11, and the record shows that the defendant understood

the waiver's significance, the waiver is both valid and enforceable. Id. We have reviewed

the plea agreement and the Fed. R. Crim. P. 11(b) hearing and conclude that Ojo’s appeal

waiver is valid and enforceable.

While counsel states that there are no meritorious grounds for appeal, he questions

whether the district court abused its discretion in denying Ojo’s motion to withdraw his

guilty plea. Ojo also challenges the denial of that motion in his informal brief. An

enforceable appellate waiver in a plea agreement will not bar appellate review of the denial

of a motion to withdraw the underlying guilty plea when the motion contains “a colorable

claim that the plea agreement . . . is tainted by constitutional error,” such as involuntariness

or ineffective assistance of counsel. United States v. Attar, 38 F.3d 727, 733 n.2

(4th Cir. 1994). But Ojo’s motion to withdraw his guilty plea did not assert any error in

the plea agreement or any other error of constitutional magnitude. Because we conclude

that Ojo’s appeal waiver is valid and enforceable and the denial of his motion to withdraw

his guilty plea falls within the scope of the appeal waiver, which the Government seeks to

enforce, we will grant the Government’s motion to dismiss in part and not review this issue.

See United States v.

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Related

Anders v. California
386 U.S. 738 (Supreme Court, 1967)
Faretta v. California
422 U.S. 806 (Supreme Court, 1975)
United States v. Frederick Keith Singleton
107 F.3d 1091 (Fourth Circuit, 1997)
United States v. Larry Lamont Bush
404 F.3d 263 (Fourth Circuit, 2005)
United States v. Mastrapa
509 F.3d 652 (Fourth Circuit, 2007)
United States v. Alex McCoy
895 F.3d 358 (Fourth Circuit, 2018)
United States v. Cortez Rogers
961 F.3d 291 (Fourth Circuit, 2020)
United States v. Christopher Singletary
984 F.3d 341 (Fourth Circuit, 2021)
United States v. Gerald Boutcher
998 F.3d 603 (Fourth Circuit, 2021)
United States v. Joseph Ziegler
1 F.4th 219 (Fourth Circuit, 2021)
United States v. Robert Cisson
33 F.4th 185 (Fourth Circuit, 2022)

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