United States v. Augustus Light ( 2022 )

United States Court of Appeals
For the Eighth Circuit
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No. 22-3367
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Augustus Quintrell Light, also known as Stow
lllllllllllllllllllllDefendant - Appellant
___________________________
No. 22-3369
___________________________
United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
Augustus Quintrell Light, also known as Stow
lllllllllllllllllllllDefendant - Appellant
____________
Appeals from United States District Court
for the District of Minnesota
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Submitted: December 13, 2022
Filed: December 22, 2022
[Unpublished]
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Before KELLY, STRAS, and KOBES, Circuit Judges.
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PER CURIAM.
Augustus Light originally received a 120-month prison sentence for
possession with intent to distribute methamphetamine and another 18 months for
violating the conditions of supervised release. See 21 U.S.C. § 841(a)(1), (b)(1)(A);
see also 18 U.S.C. § 3583(e)(3). We remanded because the 18-month revocation
sentence exceeded the statutory maximum. See United States v. Light, No. 21-
2659/2677, 2022 WL 1252227, at *1 (8th Cir. Apr. 28, 2022) (unpublished per
curiam). The district court 1 then sentenced him to seven months in prison, two
months below the maximum available sentence. In a pro se appeal, Light argues
that he should have been able to withdraw his guilty plea.
We conclude that the district court did not abuse its discretion in concluding
otherwise. See United States v. Cruz, 643 F.3d 639, 641 (8th Cir. 2011). The
government fulfilled its obligations under the plea agreement, which did not mandate
an illegal sentence. See United States v. Greatwalker, 285 F.3d 727, 729–30 (8th
Cir. 2002) (noting that defendants are not entitled to withdraw guilty pleas when a
legal sentence “can be reconciled with the plea agreement”). And even assuming
that a challenge to the performance of standby counsel could be viable, it must await
collateral review. See United States v. Adkins, 636 F.3d 432, 434 (8th Cir. 2011).
We accordingly affirm the judgment of the district court.
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1
The Honorable Paul A. Magnuson, United States District Judge for the
District of Minnesota.
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