## Facts

- A federal grand jury in the Southern District of West Virginia indicted Charles York Walker, Jr. on multiple counts of distributing heroin and fentanyl in violation of 21 U.S.C. § 841(a)(1), and one count of being a felon in possession of a firearm in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2).
- The case arose during an acute heroin and synthetic-opioid overdose crisis in West Virginia, where fentanyl posed an especially high risk of fatal overdose.
- The United States and Walker negotiated a plea agreement intended to resolve the case without a jury trial.
- Under the agreement, the government filed a single-count information charging Walker with possession with intent to distribute heroin (based on conduct dated July 14, 2016), and Walker agreed to plead guilty to that information.
- In exchange, the government agreed to seek dismissal of the earlier multi-count indictment, including the fentanyl-distribution counts and the firearm charge.
- Walker entered a guilty plea to the information, and the court accepted the plea itself but deferred acceptance of the plea agreement pending review of the Presentence Investigation Report (PSR), as Rule 11 permits.
- After reviewing the PSR, the court considered Walker’s background and criminal record, including repeated prior convictions and facts suggesting ongoing involvement in drug dealing.
- The court also considered the community’s interest in public criminal adjudication—particularly for heroin and fentanyl offenses—in light of the overdose crisis.

## Issues

1. Under Federal Rule of Criminal Procedure 11(c), may a district court reject a plea agreement even when the defendant’s guilty plea is valid, based on the court’s view that the bargain is not in the public interest?
2. In deciding whether to accept a plea agreement, may the court consider community interests in public adjudication and jury participation, in addition to the defendant’s history and the nature of the charged conduct?
3. May the court reject a plea agreement that would dismiss multiple distribution and firearm counts in exchange for a guilty plea to a single heroin charge where the court concludes the resolution does not adequately reflect the seriousness of the case?

## Decision

- The court rejected the parties’ plea agreement.
- The court held that Rule 11 gives the district court broad discretion to accept or reject plea agreements and that the rule does not limit the considerations a judge may weigh in exercising that discretion.
- The court concluded the proposed agreement was not in the public interest because it would avoid public adjudication—including the public function served by jury trials—in a serious heroin/fentanyl case during a severe overdose crisis.
- The court also relied on information in the PSR, including Walker’s criminal history and conduct described in the report, to find the proposed charge reduction and dismissal package inadequate.
- The court left intact its prior acceptance of Walker’s guilty plea to the information but declined to approve the agreement that required dismissal of the indictment.

## Legal Principles

- Federal Rule of Criminal Procedure 11 requires judicial approval of plea agreements; a plea agreement has no binding effect on the court unless the court accepts it.
- A court may accept a guilty plea while deferring the decision whether to accept the plea agreement until after reviewing the PSR.
- Because Rule 11 does not specify a mandatory test for approval, a district court has broad discretion to accept or reject a negotiated plea agreement.
- In exercising that discretion, a court may consider the public interest, including transparency in criminal adjudication and the community’s role in criminal trials.
- A court may reject a plea agreement when it concludes the agreement would shift serious criminal adjudication away from open court for reasons of convenience at the expense of public confidence in the criminal justice process.
- In evaluating whether a plea agreement serves the public interest, the court may weigh the seriousness of the charged offenses, the proposed dismissals, and defendant-specific facts reflected in the PSR.

## Conclusion

In United States v. Walker, the district court used its discretion under Rule 11 to reject a negotiated plea agreement that would have resolved a multi-count heroin/fentanyl and firearm indictment through a guilty plea to a single heroin count, concluding—based on the PSR, the seriousness of the alleged conduct, and the community interest in open adjudication during West Virginia’s overdose crisis—that the bargain was not in the public interest.


United States v. Walker, 423 F. Supp. 3d 281 (2017)