United States v. Wright: Limiting Constitutional Review on Motions to Withdraw Guilty Pleas to the Statute of Conviction

1. Introduction

United States v. Billy Allen Wright, decided by the United States Court of Appeals for the Sixth Circuit on 22 July 2025, arose from a plea bargain structured to eliminate a mandatory-minimum exposure under 18 U.S.C. § 924(e) (the “Armed Career Criminal Act,” ACCA). The Government agreed to dismiss a felon-in-possession count under § 922(g)(1) and its ACCA enhancement if Wright pleaded guilty to possession of a stolen firearm under § 922(j). After the district court accepted the plea and imposed the agreed 120-month sentence, Wright sought to withdraw his plea, asserting that N.Y. State Rifle & Pistol Ass’n v. Bruen rendered all three statutes (§§ 922(g)(1), 922(j), and 924(e)) unconstitutional as applied to him. The district court denied the motion, holding that § 922(j) survived Bruen and refusing to address the constitutionality of §§ 922(g)(1) and 924(e) because Wright had not been convicted under them. On appeal, Wright argued that the court should have assessed the allegedly unconstitutional statutes he had “bargained away.” The Sixth Circuit affirmed, articulating a clear rule: when evaluating a presentence motion to withdraw a guilty plea, a district court’s constitutional analysis need only reach the statute underlying the defendant’s actual plea of conviction, not dismissed or uncharged statutes implicated in the bargaining process.

2. Summary of the Judgment

Issue on Appeal: Whether the district court abused its discretion by declining to analyze the constitutionality of §§ 922(g)(1) and 924(e) when denying Wright’s motion to withdraw his § 922(j) guilty plea.
Holding: No abuse of discretion. The district court properly confined its Bruen analysis to § 922(j), the only statute to which Wright pleaded guilty.
Disposition: Judgment of the district court AFFIRMED; Government’s motion for judicial notice that the underlying criminal cases were related GRANTED.
New Precedent: In the Sixth Circuit, Rule 11(d)(2)(B) motions require the defendant to supply a “fair and just reason” tied to the charge of conviction; courts are not obliged to examine the constitutionality of charges that were dismissed pursuant to a plea agreement.

3. Detailed Analysis

3.1 Precedents Cited

New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022) – Set the modern test for Second-Amendment challenges, requiring government to justify firearm regulations with historical analogues. Bruen is the doctrinal backdrop for Wright’s arguments.
United States v. Carson, 32 F.4th 615 (6th Cir. 2022) – Articulates abuse-of-discretion review of plea-withdrawal denials and recites the seven “Bazzi factors.”
United States v. Ellis, 470 F.3d 275 (6th Cir. 2006) – Defines abuse of discretion as reliance on clearly erroneous facts or erroneous legal standards.
United States v. Triplett, 828 F.2d 1195 (6th Cir. 1987) – Places the burden on the defendant to establish a fair and just reason for withdrawal.
Bazzi, 94 F.3d 1025 (6th Cir. 1996) – Provides the non-exclusive factors for evaluating a Rule 11(d) motion.
Wooden v. United States, 595 U.S. 360 (2022) – Interprets ACCA’s “occasions different” clause; relevant to Wright’s bargaining calculus but unchanged since plea entry.

3.2 Court’s Legal Reasoning

The panel framed the question narrowly: Was it error for the district court to disregard Wright’s Bruen-based assault on dismissed statutes when ruling on a motion that concerned his plea to § 922(j)? Key steps in the reasoning:

Rule 11(d) Structure: A defendant may withdraw a pre-sentence guilty plea only for a “fair and just reason.” The focus is on the voluntary, knowing, and intelligent nature of the plea actually entered.
Charge-Specific Inquiry: Because Wright pleaded solely to § 922(j), the constitutional validity of that statute was dispositive. The legal status of charges dismissed in exchange for the plea is collateral unless they affect the voluntariness of the plea.
Bruen Application Limited: After a meticulous Bruen analysis, the district court found § 922(j) historically supported. Wright did not appeal that holding; therefore, no substantive Second Amendment question remained.
No Changed Circumstances: Wright’s claimed “new” caselaw (e.g., Range, Bullock) merely applied Bruen and, in some instances, had already been vacated or reversed. Thus they did not create a “sea change” warranting plea withdrawal.
Contractual Framing Rejected: Wright’s “swap” argument treats plea bargains as contracts conferring continuing rights in the dismissed counts. The court countered that once the Government dismissed those counts, they no longer defined Wright’s criminal exposure; thus they could not supply a “fair and just” basis to undo the existing conviction.

3.3 Impact of the Decision

The Sixth Circuit’s opinion, though unpublished, crystallizes a principle likely to guide district courts across the Circuit:

“When assessing a presentence motion to withdraw a guilty plea, constitutional attacks must bear on the statute of conviction. Dismissed or never-charged counts, even if part of the plea calculus, are legally irrelevant unless their status undermines the voluntariness of the plea.”

Practical Effect on Plea Litigation: Defendants cannot leverage post-plea doctrinal shifts affecting dismissed charges as an automatic ticket to undo a bargain.
Second-Amendment Landscape: The decision insulates § 922(j) guilty pleas from collateral challenges based on uncertainty surrounding § 922(g)(1) or ACCA.
Plea-Bargain Strategy: Counsel negotiating pleas must recognize that future constitutional challenges to dismissed counts may be unavailable on withdrawal motions; any Bruen-style claims must be preserved before pleading or waived.
Judicial Economy: By limiting the scope of constitutional inquiry, the ruling streamlines Rule 11(d) proceedings and reduces evidentiary hearings focused on legally nonexistent charges.

4. Complex Concepts Simplified

Rule 11(c)(1)(C) Plea: A plea agreement binding the court to a specific sentence if accepted. Here, 120 months.
Fair and Just Reason: A flexible standard under Rule 11(d). The defendant must articulate a credible, non-speculative reason to undo the plea—e.g., new evidence, ineffective assistance, or a fundamental legal change.
Section 922(g)(1): Prohibits firearm possession by felons.
Section 922(j): Criminalizes knowing possession of a stolen firearm.
Section 924(e) (ACCA): Imposes a 15-year mandatory minimum for offenders with three prior serious drug or violent felonies who violate § 922(g).
Bruen Test: A two-step inquiry: (1) does the challenged conduct implicate the plain text of the Second Amendment? (2) if so, does the Government demonstrate a historically analogous regulation? If not, the statute is unconstitutional.
“Occasions Different” Clause: Under ACCA, prior offenses must be committed on different occasions to count separately toward the three-strike threshold. Wooden clarified the interpretation.

5. Conclusion

United States v. Wright solidifies a pragmatic boundary around plea-withdrawal litigation: district courts need not conduct constitutional autopsies on charges that ceased to exist after a plea bargain. The Sixth Circuit’s reaffirmation of this charge-specific approach under Rule 11(d) preserves the stability of plea agreements and curtails defendants’ ability to resurrect dismissed counts through Bruen-driven motions. Though the opinion is marked “not for publication,” its reasoning will likely resonate in future cases where defendants attempt to parlay evolving Second Amendment doctrine into a redo of fully accepted and executed plea bargains. The key takeaway for counsel is clear: constitutional objections to all potential charges must be raised before entering a plea, or they will be sidelined once the conviction rests on a single, unchallenged statute.