## Facts

- Mark Allen Youngs waived indictment and pleaded guilty in the U.S. District Court for the Western District of New York to producing child pornography (18 U.S.C. § 2251(a)) and possessing child pornography (18 U.S.C. § 2252A(a)(5)(B), (b)(2)).
- The plea agreement described the mandatory minimum and maximum imprisonment terms, potential fines and assessments, and supervised release terms (up to life).
- During the Rule 11 colloquy, the district court advised Youngs about the imprisonment ranges, supervised release exposure, forfeiture of computer equipment, and post-release sex-offender registration obligations; Youngs stated he understood and entered guilty pleas.
- The district court later sentenced Youngs to concurrent terms of 240 months (production) and 120 months (possession), plus 40 years of supervised release with conditions.
- The district court did not advise Youngs that, after completing his prison term, he could potentially face federal civil commitment as a “sexually dangerous person” under 18 U.S.C. § 4248.

## Issues

1. Whether due process or Federal Rule of Criminal Procedure 11 requires a district court, before accepting a guilty plea to sex offenses, to advise the defendant of potential post-sentence civil commitment under 18 U.S.C. § 4248.
2. Whether § 4248 civil commitment is a “direct consequence” of a guilty plea (requiring disclosure) or a “collateral consequence” (not requiring disclosure).

## Decision

- The Second Circuit affirmed the judgment of conviction.
- The court held that possible civil commitment under 18 U.S.C. § 4248 is a collateral consequence of the guilty plea.
- Because § 4248 commitment is collateral, neither due process nor Rule 11 required the district court to advise Youngs of that possibility before accepting the plea.
- The court concluded the plea remained knowing, intelligent, and voluntary because Youngs was properly advised of the direct penal consequences addressed by Rule 11.

## Legal Principles

- Rule 11 requires a court accepting a guilty plea to ensure the defendant understands the plea’s direct consequences, including applicable mandatory minimums, maximum penalties, and supervised release.
- Due process requires a guilty plea to be knowing, intelligent, and voluntary; this generally requires disclosure of direct consequences but not collateral consequences.
- A consequence is “direct” when it has a definite, immediate, and largely automatic effect on the range of punishment; consequences that are contingent and depend on later discretionary decisions by other actors are typically “collateral.”
- Federal civil commitment under 18 U.S.C. § 4248 is a separate civil proceeding, not part of the criminal sentence, and depends on later certifications and judicial findings; it therefore does not follow automatically from the plea.

## Conclusion

The Second Circuit held that potential post-sentence civil commitment under 18 U.S.C. § 4248 is a collateral consequence of a guilty plea, so Rule 11 and due process do not require district courts to warn defendants of that possibility during the plea colloquy.


United States v. Youngs, 687 F.3d 56 (2d Cir. 2012)