United States v. Lorquet: Reinforcing the Buckles Framework and the Presumption of Veracity in Plea-Withdrawal Motions

I. Introduction

In United States v. Andre Lorquet, No. 24-10902 (11th Cir. May 12, 2025) (unpublished), the Eleventh Circuit revisited the standards governing post-plea, pre-sentence motions to withdraw guilty pleas under Federal Rule of Criminal Procedure 11(d)(2)(B). The panel, comprising Newsom, Grant, and Anderson, JJ., affirmed the Southern District of Florida’s denial of Mr. Lorquet’s motion, thereby solidifying two intertwined principles:

The continued centrality of the four Buckles factors in assessing whether a defendant has shown a “fair and just reason” for withdrawal; and
The powerful (though rebuttable) presumption that sworn statements made during a Rule 11 plea colloquy are truthful.

Although the opinion is unpublished, it provides a meticulous application of existing precedent and clarifies how lower courts should weigh credibility disputes—especially when the defendant’s post-plea assertions conflict with earlier sworn statements and are unsupported by objective evidence.

II. Summary of the Judgment

After pleading guilty to one count of money laundering in violation of 18 U.S.C. § 1957, Mr. Lorquet sought to withdraw his plea, claiming he was pressured by counsel and did not enter the plea knowingly or voluntarily. The district court—adopting a magistrate judge’s report and recommendation—denied the motion. On appeal, the Eleventh Circuit held that:

The district court did not abuse its discretion because the first two Buckles factors (close assistance of counsel; knowing and voluntary plea) weighed strongly against withdrawal.
The appellant’s subsequent, unsupported claims of pressure and coercion lacked credibility in light of his contrary sworn testimony during the Rule 11 colloquy.
Where factors one and two decisively favor the government, the court need not give “considerable weight or attention” to the remaining factors (judicial efficiency and government prejudice).
The timing of the renewed withdrawal motion—filed months after the plea and only after adverse guideline rulings—further undermined the defendant’s position.

Accordingly, the Eleventh Circuit affirmed the district court’s decision in its entirety.

III. Analysis

A. Precedents Cited

The opinion draws heavily on long-standing Eleventh Circuit authorities:

United States v. Buckles, 843 F.2d 469 (11th Cir. 1988) – established the four-factor test for plea withdrawals.
United States v. Gonzalez-Mercado, 808 F.2d 796 (11th Cir. 1987) – emphasized that adverse weight on factors 1 and 2 permits the court to discount factors 3 and 4.
United States v. Medlock, 12 F.3d 185 (11th Cir. 1994) – articulated the strong presumption that statements made at a plea colloquy are true.
United States v. Rogers, 848 F.2d 166 (11th Cir. 1988) – placed a “heavy burden” on defendants seeking to prove those statements false.
United States v. Weaver, 275 F.3d 1320 (11th Cir. 2001); United States v. Brehm, 442 F.3d 1291 (11th Cir. 2006) – both reiterating the “abuse of discretion” standard of review.

Collectively, these cases form a consistent line that grants district courts substantial latitude, provided they articulate their reasoning and make credibility findings.

B. Legal Reasoning of the Court

Standard of Review: The Circuit reiterated that denial of a withdrawal motion is reviewed for abuse of discretion and will be reversed only if “arbitrary or unreasonable.”
Application of Buckles Factors:
- Factor 1 – Close Assistance of Counsel: The defendant admitted under oath that he had fully discussed the plea and was satisfied with counsel. His later claims were deemed vague and unsupported.
- Factor 2 – Knowing & Voluntary Plea: The plea colloquy confirmed comprehension; no promises or threats were made. Unsupported later claims of learning disabilities or coercion were rejected as not credible.
- Factors 3 & 4 – Judicial Resources & Government Prejudice: Because factors 1 and 2 weighed decisively against withdrawal, the court, under Gonzalez-Mercado, properly afforded minimal weight to these prongs.
Timing Considerations: Withdrawal was sought months after the plea, and only after unfavorable guideline rulings (obstruction enhancement; denial of acceptance-of-responsibility reduction), suggesting strategic motive rather than genuine confusion or coercion.
Credibility Determinations: The district court’s acceptance of the magistrate judge’s credibility findings—especially the preference for contemporaneous sworn statements over later contradictory assertions—was central and entitled to deference.
Abandonment Doctrine: Issues not briefed on appeal (e.g., alleged external threats, literacy issues) were deemed abandoned in line with United States v. Campbell, 26 F.4th 860 (11th Cir. 2022).

C. Potential Impact

While unpublished and thus non-binding, the opinion:

Provides a clear roadmap for district judges handling plea-withdrawal motions, emphasizing the importance of on-the-record colloquies and written factual findings regarding credibility.
Alerts defense counsel that generic, uncorroborated claims of “pressure” increasingly fail to satisfy the heavy burden needed to overcome the presumption of veracity.
Signals to prosecutors that, if factors 1 and 2 are solid, they need not expend extensive effort proving prejudice or resource conservation.
May influence future appellate panels—even outside the Eleventh Circuit—when considering similar factual scenarios, because the logic dovetails with nationwide jurisprudence emphasizing finality of guilty pleas.

IV. Complex Concepts Simplified

Rule 11(d)(2)(B): Allows a defendant, after the plea is accepted but before sentencing, to withdraw the plea if he shows a “fair and just reason.” Think of it as a limited “grace period” to undo a guilty plea.
Buckles Factors: A four-part test (counsel, voluntariness, judicial resources, government prejudice) used to decide Rule 11 withdrawal motions.
Presumption of Veracity: Courts start from the assumption that what a defendant says under oath in court is true. Overcoming that requires concrete, credible evidence, not mere after-the-fact assertions.
Abuse of Discretion Review: An appellate court will not second-guess the trial judge unless the decision lacks a rational basis. It’s a deferential standard.
Guideline Enhancements (e.g., § 3C1.1): Numerical increases in offense level under the U.S. Sentencing Guidelines for conduct like obstruction of justice, which can materially raise the defendant’s advisory sentence range.

V. Conclusion

United States v. Lorquet underscores that guilty pleas are solemn acts not easily undone. The Eleventh Circuit’s application of the Buckles framework—combined with an unwavering presumption in favor of the truthfulness of plea-colloquy statements—reinforces finality, conserves judicial resources, and safeguards the integrity of Rule 11 proceedings. Practitioners should view the case as a cautionary reminder: assertions of coercion or misunderstanding must be promptly raised, fully developed, and corroborated, or they will almost certainly fail.