United States v. Carlos Vance Watts, Jr.

CourtCourt of Appeals for the Sixth Circuit
DecidedJanuary 28, 2025
Docket24-1043
StatusUnpublished

This text of United States v. Carlos Vance Watts, Jr. (United States v. Carlos Vance Watts, Jr.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. Carlos Vance Watts, Jr., (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0048n.06

Case No. 24-1043

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Jan 28, 2025 ) UNITED STATES OF AMERICA, KELLY L. STEPHENS, Clerk ) Plaintiff - Appellee, ) ) v. ON APPEAL FROM THE UNITED ) STATES DISTRICT COURT FOR THE ) CARLOS VANCE WATTS, JR., WESTERN DISTRICT OF MICHIGAN ) Defendant - Appellant. ) OPINION ) )

Before: CLAY, GIBBONS, and GRIFFIN, Circuit Judges.

JULIA SMITH GIBBONS, Circuit Judge. After Appellant Carlos Watts ran away from a

halfway house without permission, he was indicted for felony escape. Watts initially planned to

go to trial and asked for a 60-day continuance to review the evidence in his case, but the district

court denied his request. Soon after, at Watts’s final pretrial conference, Watts changed his mind

and decided to plead guilty. But then Watts changed his mind again and filed a motion to withdraw

his guilty plea and also accused the district judge of bias because of an alleged federal investigation

into prior threats Watts had purportedly made against the judge’s life. The district court rejected

Watts’s motion to withdraw his guilty plea and the district judge also decided not to recuse himself

from the case. At sentencing, the district court sentenced Watts to a within-Guidelines term of 14

months in prison, which Watts completed in July 2024. We now affirm the district court’s

decisions on Watts’s guilty plea and his request for the judge to recuse. We conclude that Watts No. 24-1043, United States v. Watts

has waived any challenge to the denial of his motion for a continuance and dismiss Watts’s

sentencing appeal as moot.

I.

Following Watts’s imprisonment for being convicted of conspiracy to possess with intent

to distribute and to distribute cocaine base and possessing a firearm in furtherance of that crime,

he was placed in a halfway house located in Kalamazoo, Michigan. Watts entered the halfway

house on July 28, 2022, and was scheduled to be released from the halfway house on April 26,

2023. As part of Watts’s placement, he was placed on electronic monitoring.

On December 10, 2022, Watts was residing in the halfway house and employed at the Park

Club of Kalamazoo. Watts’s girlfriend, H.K., left home to pick up Watts from work and she was

never seen or heard from again. The next day, investigators discovered H.K.’s vehicle, abandoned

on the side of the road, with her blood on the front and back seat. About a half mile away, officers

found women’s clothing belonging to H.K. in a field, later found to contain the DNA of H.K. and

Watts. The next day, December 11, 2022, Watts called the police to make a harassment complaint

against H.K.’s brother, Tim Kelley. Kelley had messaged Watts a picture of an AR15 along with

a video stating that he was going to kill Watts and his brother. Kelley made these threats because

he believed Watts was responsible for his sister’s disappearance and warned Watts in a cryptic

message that his sister “better turn up.”

The next day, December 12, 2022, Watts fled the halfway house and removed his electronic

monitoring device sometime around then. According to Watts, he ran because he feared Kelley or

other members of Kelley’s gang, the Gangster Disciples, would seek him out and kill him at the

halfway house. On December 14, 2022, police located Watts at a home in Michigan. Watts

initially barricaded himself in the home before surrendering without incident.

-2- No. 24-1043, United States v. Watts

On March 28, 2023, Watts was indicted for felony escape. Watts’s case proceeded toward

trial. The district court set the final pretrial conference for July 3, 2023, and the start date of the

trial on July 18, 2023. On June 27, 2023, Watts filed an unopposed motion to delay the trial for

60 days because of the government’s disclosure of rebuttal evidence. Watts requested further time

to review the evidence and potentially retain an expert witness. The district court denied Watts’s

motion without prejudice, reasoning that the felony-escape charge was simple on its face and

involved very little evidence. The district court noted that if it later decided to allow Watts to

present an affirmative defense of justification at trial, it would reassess the motion for a

continuance at the pretrial conference, as the justification defense would make the case

significantly more complicated.

At the July 3 pretrial conference, the district court began by stating that the “fundamental

issue we have to decide . . . [is] the justification defense and whether it goes to the jury or not, and

if it does what the implications are for each side in terms of evidentiary presentations[.]” DE 45,

Final Pretrial Conference Tr., Page ID 201–02. However, Watts’s counsel indicated that Watts

may be open to resolving this case before the conference began and asked for a brief recess. When

the parties reconvened later that day, Watts’s counsel indicated he was ready to enter a guilty plea.

There was no plea agreement. Watts was sworn in, and after a plea colloquy where Watts was

advised of his rights, the court confirmed that Watts’s plea was knowing, intelligent, voluntary,

and proper. Although the court acknowledged that Watts appeared to be stressed and emotional

at times, the court was satisfied that he was competent to plead guilty. The court confirmed that

Watts understood that if he pleaded guilty, all that would be left for the court to do would be

sentencing. The court also confirmed the facts of the charged conduct, and Watts admitted to

cutting his tracking device and leaving the halfway house on December 12 without permission.

-3- No. 24-1043, United States v. Watts

A few days later, however, Watts submitted a letter to the district court stating that he

wanted to withdraw his guilty plea because it was allegedly entered when he was not in the right

state of mind. In a separate letter, Watts asked for new counsel, claiming his lawyer had been

ineffective in advising him to plead guilty.

Watts’s counsel then moved to withdraw. The court held a hearing on and granted the

motion. The district court also advised Watts that he could discuss with his new counsel his

decision to withdraw his guilty plea. Right before the hearing concluded, Watts asked for a change

of venue, asserting that there was an ongoing federal investigation against him for alleged threats

he made against the district court judge’s life. The district court judge responded that he had never

heard of these threats or the investigation, and thus, there was no reason for him to consider

recusing himself from the case.

In another letter submitted to the court in early August 2023, Watts reiterated his argument

that he should be allowed to withdraw his guilty plea. Watts again mentioned the supposed federal

investigation into threats he had made against the district court judge’s life but assured the court

that the allegations against him were false.

Watts, with his new counsel, moved to withdraw his guilty plea. After a hearing, the district

court rejected the motion, finding that Watts failed to show a fair and just reason for withdrawing

his guilty plea. In reaching this conclusion, the district court balanced the seven factors that this

Circuit considers in determining whether a defendant has shown a fair and just reason for

withdrawal.

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United States v. Carlos Vance Watts, Jr., Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-carlos-vance-watts-jr-ca6-2025.