United States v. Bates

After pleading guilty to possessing child pornography in violation of 18 U.S.C. § 2252A(a)(5)(B) and being sentenced to the ten-year mandatory minimum under 18 U.S.C. § 2252A(b)(2), 1 defendant appeals from his conviction on the grounds that (1) his guilty plea was unknowing because, at the time of his plea, he was not informed of the mandatory minimum; (2) his prior conviction for indecent assault on a minor should not have served as a predicate for the mandatory minimum because he did not knowingly waive his right to counsel before pleading guilty to that offense; and (3) the prior…