The Second Circuit Court of Appeals affirmed a district court's acceptance of a guilty plea from Steve Boria, who had taken medications for bipolar disorder and sleeping problems the night before pleading guilty to drug conspiracy and firearm charges. The appeals court ruled that the district court's inquiry into Boria's mental state was sufficient under Federal Rule of Criminal Procedure 11.
In *United States v. Boria* (2d Cir. 2026), the defendant challenged his guilty plea on grounds that the district court failed to adequately explore the effects of his psychiatric medications during the plea colloquy. Boria, also known as "Chrome," faced charges of conspiring to distribute cocaine and possessing a firearm in connection with drug trafficking.
The case originated in the U.S. District Court for the Southern District of New York under Judge Ronnie Abrams. During Boria's plea hearing, the district court learned that he had taken medications for his mental health conditions the previous evening. Rather than accepting the plea without inquiry, Judge Abrams conducted follow-up questioning to ensure Boria understood the proceedings and felt "clearheaded."
On appeal, Boria argued that the district court's inquiry was insufficient and violated both Rule 11 and his constitutional rights. He contended that the court should have conducted a more extensive investigation into the side effects and other impacts of his medications before accepting his guilty plea.
The Second Circuit panel, consisting of Circuit Judges Kearse, Lohier, and Park, disagreed with Boria's position. The court held that the district court fulfilled its Rule 11 obligation by confirming that Boria understood the proceedings and felt mentally clear during the plea colloquy.
Writing for the majority, the court emphasized that "Boria's conduct during the plea hearing raised no red flags." The panel noted that Rule 11 requires courts to "explore on the record defendant's ability to understand the nature and consequences of his decision to plead guilty," but does not mandate a specific form of inquiry when no concerning behavior is observed.
The appeals court cited *United States v. Rossillo* (2d Cir. 1988), which established the standard for judicial inquiry into a defendant's competency during plea proceedings. Under *Rossillo*, courts must ensure that defendants understand their plea and its consequences, but the extent of required inquiry depends on the circumstances presented during the hearing.
The Second Circuit found that the district court's questions about Boria's mental clarity were appropriate given his apparent competence during the proceedings. The court noted that Boria demonstrated understanding of the charges against him and the consequences of his guilty plea throughout the hearing.
In addressing Boria's constitutional claims, the appeals court applied a plain error standard of review. The court concluded that even if the district court's inquiry was inadequate, Boria failed to demonstrate that any error affected his substantial rights. Specifically, the court found "no reasonable probability that he would not have pleaded guilty but for the alleged error."
Judge Lohier filed a separate opinion concurring in part and concurring in the judgment, though the specific details of his concurrence were not detailed in the available opinion excerpt.
The decision reflects the Second Circuit's approach to balancing judicial efficiency with defendant protection in plea proceedings. While courts must ensure that defendants understand their pleas and are competent to enter them, the ruling suggests that extensive psychiatric evaluation is not required when defendants appear lucid and responsive during the hearing.
The case also highlights the intersection of mental health treatment and criminal proceedings. As more defendants receive treatment for psychiatric conditions, courts must navigate questions about medication effects on competency while avoiding unnecessary delays in case resolution.
Boria's case demonstrates that disclosure of medication use alone does not invalidate a guilty plea or require extensive judicial inquiry. Instead, courts may rely on their observations of defendant behavior and targeted questioning to assess competency.
The ruling provides guidance for district courts handling similar situations where defendants have taken psychiatric medications before court proceedings. The decision suggests that reasonable follow-up questions about mental clarity, combined with observation of defendant behavior, can satisfy Rule 11 requirements.
The affirmed conviction means Boria's guilty plea to conspiracy to distribute cocaine and firearm possession charges stands. The case was prosecuted in the Southern District of New York as case number 17-cr-00142.
This decision adds to Second Circuit precedent on plea validity and competency standards, reinforcing that courts have discretion in determining the appropriate level of inquiry based on the specific circumstances of each case. The ruling balances defendant rights with judicial efficiency in processing criminal cases where mental health medications are involved.