United States v. Jeffery Lewis

CourtCourt of Appeals for the Eleventh Circuit
DecidedApril 30, 2026
Docket23-12457
StatusUnpublished

This text of United States v. Jeffery Lewis (United States v. Jeffery Lewis) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh 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. Jeffery Lewis, (11th Cir. 2026).

Opinion

USCA11 Case: 23-12457 Document: 49-1 Date Filed: 04/30/2026 Page: 1 of 19

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 23-12457 ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

JEFFERY DEROY LEWIS, a.k.a. 2500, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Northern District of Georgia D.C. Docket No. 4:21-cr-00008-SDG-WEJ-1 ____________________

Before BRANCH, LUCK, and LAGOA, Circuit Judges. LUCK, Circuit Judge: While serving a life sentence for felony murder, Jeffery Lewis conspired to smuggle drugs into a Georgia state prison. He was indicted on one count of conspiracy to possess with the intent USCA11 Case: 23-12457 Document: 49-1 Date Filed: 04/30/2026 Page: 2 of 19

2 Opinion of the Court 23-12457

to distribute controlled substances—marijuana and methampheta- mine—and one count of conspiracy to commit bribery. Lewis ac- cepted a plea agreement in which he agreed to plead guilty to the controlled substances charge and the government agreed to drop the bribery charge and recommend imprisonment concurrent with his state sentence. At his change-of-plea hearing, Lewis admitted that he was guilty of the drug conspiracy but denied that it involved methamphetamine. When he later realized that the district court could still sentence him based on his relevant conduct involving methamphetamine, he repeatedly tried to withdraw his guilty plea. The district court denied Lewis’s motions, found that his conspir- acy involved methamphetamine, and imposed a consecutive sen- tence. Lewis now appeals the district court’s acceptance of his guilty plea and its denial of his motions to withdraw it. He argues that the district court plainly erred in accepting his plea because (1) it was “counter to the justice system,” (2) he didn’t fully under- stand the consequences of pleading guilty, and (3) he wasn’t com- petent to plead guilty. He also contends that, given the totality of the circumstances, the district court abused its discretion in deny- ing his motions to withdraw his plea. After careful review, and with the benefit of oral argument, we affirm. I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY Lewis is serving a life sentence (plus fifteen years) in Georgia state prison for felony murder. During the first five years of his incarceration, he committed and pleaded guilty to five more state- USCA11 Case: 23-12457 Document: 49-1 Date Filed: 04/30/2026 Page: 3 of 19

23-12457 Opinion of the Court 3

law offenses: three counts of possessing a prohibited cell phone, one count of possessing marijuana, and one count of obstructing a law enforcement officer. He was sentenced to time served for each of those offenses. His next offenses were federal. Eight years into his life sen- tence, Lewis involved himself in a scheme to smuggle drugs into prison through a bribed correctional officer. He was indicted on two counts. The first count charged him with conspiracy to pos- sess and distribute controlled substances—methamphetamine and marijuana. See 21 U.S.C. §§ 841(a)(1), 841(b)(1)(C)–(D), 846. The second charged him with conspiracy to bribe a state agent. See 18 U.S.C. § 666(a)(2). He pleaded not guilty at his initial appearance. The Competency Evaluations Lewis moved for and received a competency evaluation. The first evaluation was inconclusive, but the second deemed him competent to stand trial. To be sure, Lewis scored very poorly on an assessment designed to measure his understanding of the charges against him—“significantly lower,” in fact, “than the group average obtained even by individuals who are incompetent.” But since he otherwise “did not display any genuine . . . impairment,” the second evaluation concluded that he was probably making an “intentional effort to portray significant intellectual deficits.” It therefore determined that he was malingering. Based on the re- sults of both evaluations, Lewis waived his competency hearing, and the district court found him competent to stand trial. USCA11 Case: 23-12457 Document: 49-1 Date Filed: 04/30/2026 Page: 4 of 19

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The Plea Agreement On September 9, 2022, Lewis changed his plea and signed a written plea agreement with the government. See Fed. R. Crim. P. 11(c)(1)(A)–(B). The government agreed to dismiss the bribery count, while Lewis agreed to plead guilty to the drug-conspiracy count. The parties also agreed to recommend that Lewis be sen- tenced to 169 months’ imprisonment, to be served concurrently with his state sentence. The agreement included a waiver of rights and acknowledg- ment of penalties. Lewis acknowledged that he faced a maximum sentence of twenty years, that the court could sentence him to that maximum, that the court would apply the United States Sentenc- ing Guidelines to his case and could therefore consider “relevant conduct” even if it connected to “dismissed counts,” and that the court could refuse to accept any sentencing recommendations re- cited in the agreement or discussed between the parties. Lewis af- firmed that, even if the district court rejected any of the recom- mendations in the agreement, he couldn’t withdraw his plea. Annexed to the agreement was Lewis’s signed statement. In it, he confirmed that no one had coerced him into pleading guilty, that he understood the charges against him and the terms of the agreement, that he’d reviewed “every part” of the agreement with his attorney, and that he “voluntarily” accepted it. He also avowed that he was “fully satisfied with the representation provided” by his attorney. USCA11 Case: 23-12457 Document: 49-1 Date Filed: 04/30/2026 Page: 5 of 19

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The Change-of-Plea Hearing The district court held a change-of-plea hearing the same day. Lewis apparently arrived in some visible discomfort; “given the way h[e] [was] acting,” the district court expressed “a little con- cern[]” about whether Lewis was “with us today.” Lewis explained that he’d been prescribed drugs for his depression and high blood pressure and that the arthritis in his left leg had flared up. He added that he had “a lot on [his] mind” and, before agreeing to proceed with his plea, looked around the courtroom “to see if [he] had somebody back there.” Still, he confirmed that he hadn’t taken any unprescribed drugs in the last week and that he “underst[ood] what[] [was] going on” notwithstanding his medication, his leg pain, and the things on his mind. During the colloquy, Lewis informed the court that he un- derstood the rights he was waiving. And despite his responses to the competency evaluation, he even reminded the court that he’d asked about a speedy-trial issue during a previous proceeding. He agreed that he was “pleading guilty . . . because [he was] guilty.” Lewis’s attorney, for his part, reported that he’d had a “very cogent conversation” with Lewis an hour and a half before the change-of- plea hearing and that Lewis had “underst[ood] everything . . . and answered questions.” The attorney stated that he had “no concerns or doubts whatsoever about his client’s competency to plead guilty.” The government then recited the elements of the drug-con- spiracy count to which Lewis was pleading guilty. It stated that it USCA11 Case: 23-12457 Document: 49-1 Date Filed: 04/30/2026 Page: 6 of 19

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could prove that, during the period charged in the indictment, Lewis had agreed with at least one other person to possess and dis- tribute a controlled substance.

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