United States of America v. Jamie L. Rayner

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted April 4, 2025
Decided April 4, 2025
Before
DIANE S. SYKES, Chief Judge
CANDACE JACKSON-AKIWUMI, Circuit Judge
JOSHUA P. KOLAR, Circuit Judge
No. 23-3335
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
JAMIE L. RAYNER,
Defendant-Appellant.
Appeal from the United States District
Court for the Southern District of Indiana,
Indianapolis Division.
No. 1:22CR00082-003
Tanya Walton Pratt,
Chief Judge.
O R D E R
Jamie Rayner pleaded guilty to conspiracy to distribute a controlled substance,
see 21 U.S.C. § 846, and conspiracy to launder monetary instruments, see 18 U.S.C.
§ 1956(a)(1)(A), (h), and was sentenced to 180 months’ imprisonment. Rayner has
appealed, but her appointed counsel asserts that the appeal is frivolous and moves to
withdraw. See Anders v. California, 386 U.S. 738, 744 (1967). Counsel explains the nature
of the case and addresses the potential issues that an appeal like this could involve.
Because the analysis appears thorough, and Rayner has not responded to counsel’s
motion, see C IR . R. 51(b), we limit our review to the subjects that counsel raises,
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

-- 1 of 3 --

No. 23-3335 Page 2
United States v. Bey, 748 F.3d 774, 776 (7th Cir. 2014). We grant the motion and dismiss
the appeal.
Rayner was indicted in 2022 for her involvement in a large drug-trafficking
operation based in Indianapolis. She later entered a guilty plea at a change-of-plea
hearing. But months later, Rayner—represented by new counsel—asserted that she was
“bullied” into making the plea and moved to withdraw it. The district judge conducted
a hearing, found Rayner not to be credible, and denied the motion. The judge proceeded
to sentence Rayner to 180 months’ imprisonment and five years’ supervised release and
ordered her to pay a $1,000 fine and a special assessment.
Counsel first considers whether Rayner could challenge the validity of the guilty
plea but correctly concludes that doing so would be frivolous. The district judge who
accepted the plea substantially complied with Federal Rule of Criminal Procedure 11
and ensured that Rayner’s plea was knowing, voluntary, and supported by an adequate
factual basis. See United States v. Davenport, 719 F.3d 616, 618 (7th Cir. 2013); F ED. R.
C RIM . P. 11(b)(2)–(3). The judge determined that Rayner understood the charges against
her, the trial rights she was waiving, the maximum penalties she faced, and the role of
the Sentencing Guidelines. See F ED. R. C RIM . P. 11(b)(1).
Counsel also considers but rightly rejects challenging the judge’s denial of
Rayner’s motion to withdraw her guilty plea. A defendant may be permitted to
withdraw her guilty plea before sentencing only for a “fair and just reason,” see F ED. R.
C RIM . P. 11(d)(2)(B), such as (1) innocence; (2) ineffective assistance of counsel; and
(3) the plea not being knowing and voluntary. United States v. Kamkarian, 79 F.4th 889,
892 (7th Cir. 2023). But the judge, who is best positioned to evaluate the voluntariness of
a defendant’s plea, see id. at 893, found that Rayner had not shown that she was bullied
into pleading guilty. The judge explained that Rayner was “very intelligent” and
presented herself “very confidently” at the hearing, carefully distinguishing which facts
and elements of the offense she accepted and which she did not. The judge also noted
that Rayner had made sworn statements under oath at the earlier plea hearing, and
such statements are presumed to be true. See United States v. Jansen, 884 F.3d 649, 655
(7th Cir. 2018). And the judge rejected Rayner’s claims of ineffective assistance and
innocence (characterizing the evidence of Rayner’s guilt as “overwhelming”). In light of
the “great deference” that we afford the judge’s findings of fact and credibility,
see Kamkarian, 79 F.4th at 893, we agree with counsel’s conclusion that any challenge to
the ruling would be frivolous.

-- 2 of 3 --

No. 23-3335 Page 3
Counsel next rightly concludes that Rayner could not raise a nonfrivolous
challenge to the judge’s guidelines calculations. The judge correctly determined that
Rayner’s guidelines range was 292–365 months for the drug-trafficking conspiracy
(based on an adjusted offense level of 40 and a criminal history category of I) and
240 months (the statutory maximum) for the laundering conspiracy. Central to the
calculations for the drug-trafficking conspiracy was drug quantity. The judge
reasonably determined, based on testimony from an agent and corroborating evidence
at sentencing, that Rayner was responsible for drugs whose converted weight
amounted to 90,000 kilograms or more—a weight corresponding to a base offense level
of 38. See U.S.S.G. § 2D1.1(a)(5), (c)(1). The judge then added two levels because Rayner
possessed a firearm during the offense, see id. § 2D1.1(b)(1), to reach an adjusted offense
level of 40. As for the laundering conspiracy, the judge correctly assessed a base offense
level of 40 to match the offense level for the underlying drug-trafficking conspiracy,
see id. § 2S1.1(a)(1), plus two levels because Rayner was convicted under 18 U.S.C.
§ 1956, see U.S.S.G. § 2S1.1(b)(2)(B). Because of the grouping rules, Rayner’s total
adjusted offense level was 42. See id. §§ 3D1.2(a)–(c), 3D1.3(a). The judge then reduced
this figure by two based on Rayner’s acceptance of responsibility. See id. § 3E1.1(a).
Counsel also rightly rejects challenging the substantive reasonableness of
Rayner’s concurrent, below-guidelines sentences for the two conspiracies. The judge
adequately justified the sentences based on the factors set forth in 18 U.S.C. § 3553(a).
She reasonably assessed Rayner’s personal history and characteristics (noting her
abusive upbringing and ongoing mental-health struggles), the seriousness of the offense
(Rayner played a “critical part” in a large drug-trafficking organization), and mitigating
factors (her lack of criminal history and role as a single mother). We agree with counsel
that Rayner could not overcome the presumption that her below-guidelines sentences
were reasonable. See United States v. Holder, 94 F.4th 695, 700 (7th Cir. 2024).
Finally, counsel correctly concludes that Rayner could not make a nonfrivolous
challenge to the conditions of supervised release or to the fine and special assessment.
Rayner’s terms of supervised release for the drug-trafficking conspiracy (five years) and
the laundering conspiracy (three years) are within the applicable statutory limits.
See 21 U.S.C. § 841(b)(1)(A); 18 U.S.C. § 3583(b)(2). Rayner’s $1,000 fine is well below the
statutory maximum, see 18 U.S.C. § 3571(B), and the $100 special assessment for each
count was statutorily required, see id. § 3013(a)(2)(A).
We thus GRANT counsel’s motion to withdraw and DISMISS the appeal.

-- 3 of 3 --