United States of America v. Billy Joe Taylor

United States Court of Appeals
For the Eighth Circuit
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No. 23-2482
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United States of America
Plaintiff - Appellee
v.
Billy Joe Taylor
Defendant - Appellant
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Appeal from United States District Court
for the Western District of Arkansas - Ft. Smith
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Submitted: July 23, 2024
Filed: July 31, 2024
[Unpublished]
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Before KELLY, GRASZ, and STRAS, Circuit Judges.
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PER CURIAM.
Before Billy Taylor pleaded guilty to money laundering and conspiracy to
commit health-care fraud, 18 U.S.C. §§ 1347, 1349, 1957, the district court1 refused
to release his seized assets and denied his request to change attorneys. Although he
1 The Honorable P.K. Holmes, III, United States District Judge for the Western
District of Arkansas.

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argues that these rulings violated his Fifth and Sixth Amendment rights, he cannot
challenge them after unconditionally pleading guilty. See Tollett v. Henderson, 411
U.S. 258, 267 (1973) (explaining that a guilty plea “break[s] . . . the chain of events,”
meaning it forecloses “independent clams relating to the deprivation of
constitutional rights” that “preceded it in the criminal process”); United States v.
Dewberry, 936 F.3d 803, 807 (8th Cir. 2019) (holding that a defendant waived a
Sixth Amendment challenge by pleading guilty). Nor can he argue that his plea was
unknowing or involuntary, given that he first raised the point in his reply brief. See
Jenkins v. Winter, 540 F.3d 742, 751 (8th Cir. 2008) (“Claims not raised in an
opening brief are deemed waived.”). Finally, his argument that appointed counsel
provided ineffective assistance will have to await collateral review. See United
States v. Ramirez-Hernandez, 449 F.3d 824, 827 (8th Cir. 2006) (explaining that
ineffective-assistance claims are “more properly raised in a separate motion under
28 U.S.C. § 2255”). We accordingly affirm the judgment of the district court.
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