US v. Mastrapa: Mastrapa pleaded guilty to being part of a conspiracy to distribute 500 grams or more of methamphetamine. However, Mastrapa had consistently denied that he had any real part in the conspiracy and was nabbed with the meth while helping two strangers (the other co-conspirators) carry some grocery bags into their hotel room. At the guilty plea hearing, Mastrapa brought this up, but the district court relied on a DEA affidavit submitted by the Government as a factual basis to accept the plea. The same issue arose at sentencing, where Mastrapa's counsel suggested that the guilty plea had been an Alford plea. The district court sentenced Mastrapa to the mandatory minimum 120 months in prison.
On appeal, Mastrapa's counsel initially filed an Anders brief. Noting concerns about the guilty plea, the Fourth Circuit requested briefing on the issue and appointed new counsel. After arguments the court concluded that the district court plainly erred by finding that there was a factual basis to support Mastrapa's guilty plea. The court concluded that Mastrapa essentially denied the mens rea element of the conspiracy charge and that it was not proven by the affidavit on which the district court relied.