Case Explained: UNITED STATES OF AMERICA v. DONALD MCDUFFIN WILLIAMS

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-07-23 The Fourth Circuit affirmed the district court’s judgment denying Donald McDuffin Williams’s motion to withdraw his guilty plea, dismissing his Speedy Trial Act claim, and upholding his sentence despite a procedural error regarding consecutive sentencing. The court applied an abuse of discretion standard to the plea withdrawal claim, requiring Williams to demonstrate a “fair and just reason” under Federal Rule of Criminal Procedure 11(d)(2)(B), specifically that he lacked close assistance of competent counsel due to an actual conflict of interest that adversely affected his lawyer’s performance under *Cuyler v. Sullivan*. The court found no such conflict or adverse effect because Williams failed to identify a plausible alternative defense strategy clearly suggested by the circumstances and did not explain how the withheld evidence would have harmed his co-defendant. Regarding the Speedy Trial Act claim, the court applied the rule that entering a guilty plea constitutes a waiver of speedy trial rights. On the issue of consecutive sentencing, the court reviewed for plain error after noting the government’s concession that the district court lacked authority to order a sentence run consecutively to an anticipated federal revocation sentence; however, the court held that this error did not affect Williams’s substantial rights because a Maryland district court subsequently ordered the revocation sentence to run consecutively in accordance with U.S.S.G. § 7B1.3(f), rendering the outcome consistent with sentencing guidelines. As a practical consequence, Williams’s conviction and 104-month imprisonment sentence remain in effect, and no further relief is granted. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.