United States v. Eileen Crowell

This case presents the question whether a person convicted of a crime may collaterally attack her conviction by moving to expunge the records of her conviction. We hold that she cannot, and we affirm the judgment of the district court.

FACTS

In 1990, a federal grand jury indicted the defendant, Eileen Crowell, on six counts, based on allegations of conspiracy to manufacture, distribute and possess with intent to distribute live marijuana plants, see 18 U.S.C: § 2; 21 U.S.C. §§ 841 , 846, and the filing of false tax returns for 1986, 1987, and 1988, see 26 U.S.C. § 7206 . The indictment also charged her husband and a third defendant.

After extensive negotiations, Crowell entered an Alford plea — that is, she pled guilty while maintaining that she was innocent, see North Carolina v. Alford, 400 U.S. 25 , 91 S.Ct. 160 , 27 L.Ed.2d 162 (1970) — to the single charge of filing a false tax return for 1986. Crowell appeared for sentencing in district court in 1991. The Government presented the evidence that it believed supported the Defendant’s plea on the tax charge. Considering the Government’s evidence against her, the district court found that there was an adequate factual basis…