United States v. Jeffery Lewis

── United States v. Jeffery Lewis ── Court: Court of Appeals for the Eleventh Circuit Date: April 30, 2026 Category: NEW USCA11 Case: 23-12457 Document: 49-1 Date Filed: 04/30/2026 Page: 1 of 19 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 23-12457 ____________________ UNITED STATES OF AMERICA, Plaintiff-Appellee, versus JEFFERY DEROY LEWIS, a.k.a. 2500, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Northern District of Georgia D.C. Docket No. 4:21-cr-00008-SDG-WEJ-1 ____________________ Before BRANCH, LUCK, and LAGOA, Circuit Judges. LUCK, Circuit Judge: While serving a life sentence for felony murder, Jeffery Lewis conspired to smuggle drugs into a Georgia state prison. He was indicted on one count of conspiracy to possess with the intent USCA11 Case: 23-12457 Document: 49-1 Date Filed: 04/30/2026 Page: 2 of 19 2 Opinion of the Court 23-12457 to distribute controlled substances—marijuana and methampheta- mine—and one count of conspiracy to commit bribery. Lewis ac- cepted a plea agreement in which he agreed to plead guilty to the controlled substances charge and the government agreed to drop the bribery charge and recommend imprisonment concurrent with his state sentence. At his change-of-plea hearing, Lewis admitted that he was guilty of the drug conspiracy but denied that it involved methamphetamine. When he later realized that the district court could still sentence him based on his relevant conduct involving methamphetamine, he repeatedly tried to withdraw his guilty plea. The district court denied Lewis’s motions, found that his conspir- acy involved methamphetamine, and imposed a consecutive sen- tence. Lewis now appeals the district court’s acceptance of his guilty plea and its denial of his motions to withdraw it. He argues that the district court plainly erred in accepting his plea because (1) it was “counter to the justice system,” (2) he didn’t fully under- stand the consequences of pleading guilty, and (3) he wasn’t com- petent to plead guilty. He also contends that, given the totality of the circumstances, the district court abused its discretion in deny- ing his motions to withdraw his plea. After careful review, and with the benefit of oral argument, we affirm. I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY Lewis is serving a life sentence (plus fifteen years) in Georgia state prison for felony murder. During the first five years of his incarceration, he committed and pleaded guilty to five more state- USCA11 Case: 23-12457 Document: 49-1 Date Filed: 04/30/2026 Page: 3 of 19 23-12457 Opinion of the Court 3 law offenses: three counts of possessing a prohibited cell phone, one count of possessing marijuana, and one count of obstructing a law enforcement officer. He was sentenced to time served for each of those offenses. His next offenses were federal. Eight years into his life sen- tence, Lewis involved himself in a scheme to smuggle drugs into prison through a bribed correctional officer. He was indicted on