Entrapment and Rule 11 Colloquy: Upholding Knowing and Voluntary Pleas in United States v. Aguilera Raudales

Introduction

United States v. Aguilera Raudales (11th Cir. Feb. 28, 2025) addresses whether a defendant’s plea of guilty to attempted sex trafficking of a minor was truly knowing and voluntary when the defendant asserted, mid‐colloquy, that he felt entrapped. The defendant, Elvin Aguilera Raudales, a Honduran national, had negotiated with an undercover officer to pay for sexual intercourse with a twelve-year-old he believed was available on a prostitution website. After entering a written plea agreement and waiving indictment, he pleaded guilty in district court and was sentenced to ten years’ imprisonment. On appeal, he claimed his plea was coerced and uninformed, particularly because he believed the government had entrapped him. The Eleventh Circuit applied plain-error review and affirmed the conviction, reinforcing the core requirements of Federal Rule of Criminal Procedure 11 and clarifying the interplay between entrapment claims and plea validity.

Summary of the Judgment

The Eleventh Circuit held, by per curiam opinion, that:

The district court fully complied with Rule 11’s “core principles” by ensuring the plea was free from coercion, that the defendant understood the nature of the charges, and that he appreciated the direct consequences of his guilty plea.
The court’s elaboration on entrapment law—distinguishing between government persuasion of an unready criminal mind and offering an opportunity to a ready offender—did not coerce the plea but served Rule 11’s requirement for a voluntary and informed admission.
Under plain‐error review, Aguilera Raudales failed to show a reasonable probability that, but for any alleged error, he would have withdrawn his plea.

Accordingly, the conviction and ten-year sentence were affirmed.

Analysis

Precedents Cited

United States v. Puentes-Hurtado, 794 F.3d 1278 (11th Cir. 2015): Held that a sentence-appeal waiver does not bar collateral attacks on the validity of the plea itself.
United States v. Roosevelt Coates, 8 F.4th 1228 (11th Cir. 2021): Clarified that when a defendant fails to raise objections in district court, appellate review of a guilty plea’s validity is for plain error.
United States v. Mosley, 173 F.3d 1318 (11th Cir. 1999): Defined the three “core principles” of Rule 11 colloquies—absence of coercion, understanding of charges, and comprehension of plea consequences.
United States v. Medlock, 12 F.3d 185 (11th Cir. 1994): Established the strong presumption that a defendant’s in-court statements during plea colloquy are true.
United States v. Dominguez Benitez, 542 U.S. 74 (2004): Held that a defendant must show a reasonable probability the outcome would have been different absent a Rule 11 error.
United States v. Moriarty, 429 F.3d 1012 (11th Cir. 2005): Explained that plain-error review applies when a defendant fails to object to plea colloquy errors in district court.

Legal Reasoning

The court’s reasoning proceeded in two main steps:

Rule 11 Compliance and “Core Principles”: The panel reviewed the plea colloquy to verify that the judge had:
- Warned the defendant of the rights he was forfeiting (trial, confrontation, presumption of innocence).
- Informed him of the statutory minimum (10 years) and maximum (life) sentences, as well as collateral consequences (mandatory deportation and ineligibility for reentry).
- Confirmed his understanding of a sentence-appeal waiver and the circumstances under which an appeal would remain available.
- Ensured no promises or threats influenced the plea.
Each time, Mr. Raudales affirmatively acknowledged comprehension.
Entrapment Inquiry Does Not Equal Coercion: Upon the defendant’s assertion of entrapment, the district court:
- Questioned him directly about his state of mind and the undercover conversations.
- Offered a simple explanation of entrapment law (distinguishing predisposition from persuasion).
- Allowed the defendant to affirm that he had the requisite criminal intent prior to government inducement.
The appellate panel found these inquiries were part of a diligent Rule 11 colloquy rather than impermissible pressure. The defendant’s repeated acknowledgments that he intended to commit the offense and that no one forced him to plead guilty confirmed voluntariness.

Having satisfied Mosley’s three core principles, the court rejected any suggestion of coercion. Under plain-error review, Mr. Raudales could not show a reasonable probability that, but for the entrapment discussion, he would have insisted on going to trial.

Impact

This decision has several important consequences for defense and trial practice:

It reaffirms that thorough Rule 11 plea colloquies—which explore even last-minute defenses such as entrapment—serve to protect, not undermine, plea voluntariness.
It clarifies that a district judge may probe a defendant’s asserted defenses during a plea hearing without fear of reversal, so long as the inquiry is framed to inform the defendant, not browbeat him.
It underscores the high bar for plain‐error reversal of guilty pleas when no contemporaneous objection is made—defendants must demonstrate a reasonable probability of a different outcome.
It serves as a model for judges and prosecutors to conduct Rule 11 colloquies with transparency, especially in cases involving complex defenses like entrapment or duress.

Complex Concepts Simplified

Rule 11 Core Principles: The three mandatory topics—coercion, charges, consequences—are designed to ensure a defendant really knows what he’s giving up.
Plain-Error Review: When a defendant fails to object in district court, an appellate court can only reverse for an obvious error that affects the defendant’s “substantial rights” and the fairness of the proceedings.
Entrapment Defense: Exists only if the government persuades someone who was not predisposed to commit the crime. If the defendant had intent before any government contact, entrapment fails.
Sentence-Appeal Waiver: A contractual waiver of appellate rights does not bar a challenge to the lawfulness of a guilty plea itself.

Conclusion

United States v. Aguilera Raudales reinforces that a comprehensive Rule 11 colloquy—which includes probing last-minute defenses such as entrapment—bolsters the knowing and voluntary nature of guilty pleas rather than undermining them. The Eleventh Circuit’s plain-error analysis confirms the heavy burden on defendants seeking reversal when they fail to object at the plea hearing. Going forward, this decision will guide lower courts in balancing rigorous inquiry into defenses with the imperative of securing informed and uncoerced guilty pleas.