United States v. Kamkarian, No. 22-2366 (7th Cir. 2023)
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FBI agents executing a search warrant at Kamkarian’s home seized computers, containing 12 videos and more than 46,000 images of child pornography. Kamkarian was released on bond and was required to participate in mental health treatment. Kamkarian attended counseling but refused to submit to a psychiatric evaluation. Kamkarian mentioned the possibility of suicide and was admitted to a hospital. During that hospital stay, Kamkarian was transported to court, Kamkarian, under oath, proceeded with a plea colloquy. The court confirmed that Kamkarian could read, write, and understand English; was able to think clearly and understand the proceedings; was fully satisfied with his counsel’s advice; had not been forced to plead guilty; and was pleading guilty freely and voluntarily. The court accepted his plea.
With new counsel, Kamkarian moved to withdraw his plea, arguing that at the time he pled guilty, he was receiving in-patient treatment for depression. He was granted a psychological evaluation but denied an interpreter. A forensic psychologist interviewed Kamkarian, reviewed his treatment records, and opined that Kamkarian had Major Depressive Disorder that did not render him incompetent to plead guilty and that he had no difficulty communicating in English. The district judge denied his motion, explaining that she recalled Kamkarian’s hearing and that he had not appeared distressed, confused, or under duress. She discredited his testimony and sentenced Kamkarian to 87 months. The Seventh Circuit affirmed. The district court’s factual findings are not clearly erroneous; the court did not abuse its discretion.
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