⚖ Oral Arguments, with Context

The United States Court of Appeals for the Eighth Circuit hears United States versus Bruce Strickland, a case that began as a drug and firearms prosecution but became a procedural puzzle about guilty pleas, acceptance, and withdrawal. Mister Strickland originally faced charges for aiding and abetting the possession with intent to distribute more than five hundred grams of methamphetamine, plus two firearms offenses. He entered into a plea agreement and pleaded guilty to a lesser charge. The district court accepted the plea and the agreement. But at sentencing, during his allocution, Mister Strickland made statements the judge found inconsistent with accepting responsibility for the crime. The judge then said he could not sentence Strickland and offered to entertain a motion to withdraw the plea. Defense counsel moved to withdraw. The plea was withdrawn, the case went to trial, and the district court allowed the government to introduce Strickland's allocution statements as evidence. The jury convicted on all counts. On appeal, Strickland argues the district court lacked authority under Federal Rule of Criminal Procedure 11 to reject the plea agreement after accepting it, and that his allocution statements should have been excluded under Rule 410. The core legal issue is whether a district court may revoke its acceptance of a plea agreement based on a defendant's allocution, and if so, whether statements made during that allocution are admissible at trial after the plea is withdrawn. The government's threshold answer is invited error: on its account, the judge's statement had no independent legal effect, and any harm flowed from Strickland's own motion to withdraw the plea.

United States v. Bruce Strickland (No. 25-3221) — U.S. Court of Appeals for the Eighth Circuit, argued June 12, 2026.