United States v. Luis Figueroa

Summary

The Third Circuit affirmed Luis Figueroa's convictions and 516-month sentence arising from a 2014 armed kidnapping, sexual assault, and assault spree. It held that his unconditional mid-trial guilty plea waived the statute-of-limitations challenge to the felon-in-possession count, and that the broadly worded limitations waiver in his withdrawn 2018 Rule 11(c)(1)(C) plea agreement remained enforceable, rendering the brandishing conviction timely. It further held that any omission of a 'forcible' element from the kidnapping instruction was harmless beyond a reasonable doubt, that the nearly eight-year pretrial delay did not violate the Sixth Amendment under the Barker factors, and that the directed finding that the assault victim was a federal employee was at most plain error without prejudice to substantial rights. No separate opinions were filed.