United States v. Youngs

687 F.3d 56 (2012)

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United States v. Youngs

United States Court of Appeals for the Second Circuit
687 F.3d 56 (2012)

  • Written by Liz Nakamura, JD

Facts

Mark Youngs (defendant) pleaded guilty to producing and possessing child pornography. Before accepting Youngs’s guilty plea, the trial court conducted a guilty-plea colloquy, also called a plea hearing, to ensure Youngs understood the direct consequences of his plea deal, including the prison term, supervised-release term, and the requirement to register as a sex offender. The trial court also explained the maximum and minimum allowable sentences for Youngs’s crimes to contextualize the plea deal. Youngs told the court he understood the consequences of his guilty plea. However, Youngs later appealed his guilty plea, arguing that his guilty plea was entered into without informed, voluntary consent because the trial court failed to inform him that he could be subject to civil commitment as a sexually dangerous predator under the Adam Walsh Child Protection and Safety Act (the Walsh Act) following his term of imprisonment. The federal government (plaintiff) challenged, arguing that Youngs did not need to be informed about the possibility of civil commitment under the Walsh Act because it was a collateral consequence of Youngs’s plea deal, not a direct consequence.

Rule of Law

Issue

Holding and Reasoning (Droney, J.)

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