United States v. Rahn Kristopher Willis, A/K/A Darin Andre Smith, 992 F.2d 489 (4th Cir. 1993). · Go Syfert
United States v. Rahn Kristopher Willis, A/K/A Darin Andre Smith, 992 F.2d 489 (4th Cir. 1993). Cases Citing This Book View Copy Cite
274 citation events (230 in the last 25 years) across 19 distinct courts.
Strongest positive: Lewis v. United States (ncwd, 2023-12-01)
Treatment trajectory · 1993 → 2026 · click a year to view as-of
1993 2009 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Lewis v. United States (2×) also: Cited "see"
W.D.N.C. · 2023 · quote attribution · 1 verbatim quote · confidence high
a guilty plea constitutes a waiver of all nonjurisdictional defects.
discussed Cited as authority (verbatim quote) Grant v. United States
W.D.N.C. · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
a guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges
discussed Cited as authority (verbatim quote) Williams v. United States
W.D.N.C. · 2020 · signal: see · quote attribution · 1 verbatim quote · confidence high
a guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.
discussed Cited as authority (verbatim quote) Kuroski v. United States
N.D.W. Va. · 2020 · signal: see · quote attribution · 1 verbatim quote · confidence high
a knowing, voluntary, and intelligent guilty plea to an offense conclusively establishes the elements of the offense and the material facts necessary to support the conviction.
discussed Cited as authority (verbatim quote) Burch v. United States
W.D.N.C. · 2020 · signal: see · quote attribution · 1 verbatim quote · confidence high
a guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.
discussed Cited as authority (verbatim quote) Turpin v. United States
W.D.N.C. · 2020 · signal: see · quote attribution · 1 verbatim quote · confidence high
a guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges
discussed Cited as authority (verbatim quote) Kinard v. United States
W.D.N.C. · 2020 · signal: see · quote attribution · 1 verbatim quote · confidence high
a knowing, voluntary, and intelligent guilty plea to an offense conclusively establishes the elements of the offense and the material facts necessary to support the conviction.
discussed Cited as authority (verbatim quote) Allen v. United States (2×) also: Cited as authority (rule)
W.D.N.C. · 2019 · quote attribution · 1 verbatim quote · confidence high
a knowing, voluntary, and intelligent guilty plea to an offense conclusively establishes the elements of the offense and the material facts necessary to support the conviction.
discussed Cited as authority (verbatim quote) Kinard v. United States
W.D.N.C. · 2019 · signal: see · quote attribution · 1 verbatim quote · confidence high
a knowing, voluntary, and intelligent guilty plea to an offense conclusively establishes the elements of the offense and the material facts necessary to support the conviction.
examined Cited as authority (verbatim quote) Guyton v. United States (2×)
N.D. Ala. · 2019 · signal: see also · quote attribution · 2 verbatim quotes · confidence high
by pleading guilty, willis relinquished his right to contest the meaning of 'firearm' or to challenge the sufficiency of the evidence presented as factual basis for his guilty plea.
discussed Cited as authority (verbatim quote) United States v. Kevin Wick
4th Cir. · 2017 · quote attribution · 1 verbatim quote · confidence high
a knowing, voluntary, and intelligent guilty plea to an offense conclusively establishes the elements of the offense and the material facts necessary to support the conviction
discussed Cited as authority (verbatim quote) United States v. Eliazar Dominguez
4th Cir. · 2016 · signal: see · quote attribution · 1 verbatim quote · confidence high
a guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.
discussed Cited as authority (verbatim quote) United States v. Wozcikiewicz
11th Cir. · 2010 · signal: see also · quote attribution · 1 verbatim quote · confidence high
by pleading guilty, the defendant relinquished his right to contest the meaning of 'firearm' or to challenge the sufficiency of the evidence presented as a factual basis for his guilty plea.
discussed Cited as authority (verbatim quote) United States v. Nelson
4th Cir. · 2007 · quote attribution · 1 verbatim quote · confidence high
a knowing, voluntary, and intelligent guilty plea to an offense conclusively establishes the ele- ments of the offense and the material facts necessary to support the conviction.
discussed Cited as authority (verbatim quote) United States v. Roy Horton (2×) also: Cited as authority (rule)
4th Cir. · 1997 · quote attribution · 1 verbatim quote · confidence high
a knowing, voluntary, and intelligent guilty plea to an offense conclusively establishes the elements of the offense and the material facts necessary to support the conviction.
discussed Cited as authority (verbatim quote) United States v. Horton (2×) also: Cited as authority (rule)
4th Cir. · 1997 · quote attribution · 1 verbatim quote · confidence high
a knowing, voluntary, and intelligent guilty plea to an offense con- clusively establishes the elements of the offense and the material facts necessary to support the conviction.
discussed Cited as authority (rule) Jenkins v. United States
W.D.N.C. · 2024 · confidence medium
First, the Petitioner’s claims of substantive error that were raised in the original Motion to Vacate were waived by Petitioner’s knowing and voluntary guilty plea and post-conviction waiver. “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Glover v. United States
W.D.N.C. · 2024 · confidence medium
Motion to Vacate A knowing and voluntary guilty plea “constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Davis v. United States
W.D.N.C. · 2023 · confidence medium
In addition to being wholly conclusory,4 Petitioner waived his claims regarding discovery, an unidentified alibi defense, and his counsel’s lack of preparation by pleading guilty. “[A] guilty plea constitutes a waiver of all nonjurisdictional defects[.]” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Burgos v. United States
W.D.N.C. · 2023 · confidence medium
Petitioner claims his attorney was ineffective for failing to move to suppress the firearm evidence as from an illegal search and seizure. “[A] guilty plea constitutes a waiver of all nonjurisdictional defects[.]” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Lurry v. United States
W.D.N.C. · 2023 · confidence medium
Moreover, Petitioner waived his Fourth Amendment claims by pleading guilty. “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Armstrong v. United States
W.D.N.C. · 2023 · confidence medium
Due Process Violation “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993). true, and the Statement of Relevant Conduct in the PSR demonstrate that all of the charged offenses were well supported by the evidence.
discussed Cited as authority (rule) Nicks v. United States
W.D.N.C. · 2023 · confidence medium
His claims were also waived by his knowing and voluntary guilty plea. “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) United States v. Jennifer Manley (2×) also: Cited "see"
4th Cir. · 2023 · confidence medium
“A knowing, voluntary, and intelligent guilty plea to an offense conclusively establishes the elements of the offense and the material facts necessary to support the conviction.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Burton v. USA - 2255
D. Maryland · 2023 · confidence medium
Set Aside Sent. 2–3.) However, “[w]hen a defendant pleads guilty, he waives all nonjurisdictional defects in the proceedings conducted prior to the entry of the plea.” United States v. Bundy, 392 F.3d 641, 644 (4th Cir. 2004) (citing United States v. White, 366 F.3d 291 , 298–99 (4th Cir. 2004); United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993)); accord United States v. Broce, 488 U.S. 563, 569 (1989) (“A plea of guilty and the ensuing conviction comprehend all of the factual and legal elements necessary to sustain a binding, final judgment of guilt and a lawful sentence.”…
discussed Cited as authority (rule) Franks v. United States
W.D.N.C. · 2022 · confidence medium
A. Pre-Plea Performance First, Petitioner argues that counsel provided ineffective assistance prior to his entry of the guilty plea by, for instance, failing to determine the accuracy of lab results concerning drug purity, adequately investigate the legality of the search and seizure, and file motions to suppress and to dismiss. [Doc. 1 at 5-6; Doc. 1-1 at 15-18]. “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Burris v. United States (2×) also: Cited "see"
W.D.N.C. · 2022 · confidence medium
A. Waiver Petitioner argues that counsel provided ineffective assistance before he pleaded guilty by failing to adequately investigate the case by, for instance, failing to file “vigorous pre-trial motions,” obtain expert witnesses, “lay the groundwork for a favorable case or trial disposition,” “obtain proper mitigation evidence for Petitioner based upon drug and mental health issues,” and investigate Petitioner’s prior convictions so that counsel could predict whether he would qualify as a career offender and provide an accurate sentencing range. [Doc. 1-1 at 5-6]. “[A] guilt…
discussed Cited as authority (rule) McManus v. United States (2×) also: Cited "see"
W.D.N.C. · 2022 · confidence medium
To satisfy Strickland’s prejudice prong, the defendant must show “there is a reasonable probability that, but for counsel's errors, he would not have pleaded guilty and would have insisted on going to trial.” Hill, 474 U.S. at 59 ; Meyer v. Branker, 506 F.3d 358, 369 (4th Cir. 2007). “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
cited Cited as authority (rule) Kendrick v. United States
W.D.N.C. · 2022 · confidence medium
No. 20 at ¶¶ 19-20); United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993); United States v. Lemaster, 403 F.3d 216, 200 (4th Cir. 2005).
discussed Cited as authority (rule) Sabatino v. United States
W.D.N.C. · 2021 · confidence medium
DISCUSSION A. Guilty Plea As a preliminary matter, “a guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) McCracken v. United States
W.D.N.C. · 2021 · confidence medium
DISCUSSION4 (A) Waiver As a preliminary matter, “a guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Brandon v. United States
W.D.N.C. · 2021 · confidence medium
Strickland, 466 U.S. at 670 . 10 (1) Waiver Petitioner appears to argue that counsel provided ineffective assistance before she pleaded guilty by failing to seek to suppress Petitioner’s statement to police, a firearm, and narcotics. “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) United States v. Craig Alston
4th Cir. · 2021 · confidence medium
Nor must the defendant be “convicted—either previously or contemporaneously—of the predicate offense, so long as the evidence was sufficient to permit the jury to find the elements of the predicate offense beyond a reasonable doubt.” United States v. Crawley, __ F.4th __, __, No. 19-7369, 2021 WL 2557790 , at *5 (4th Cir. June 23, 2021) (brackets and internal quotation marks omitted). “[A] voluntary and intelligent plea of guilty is an admission of all the elements of a formal criminal charge and . . . all material facts alleged in the charge.” United States v. Willis, 992 F.2d 489…
discussed Cited as authority (rule) Weeks v. United States
W.D.N.C. · 2021 · confidence medium
Strickland, 466 U.S. at 670 . (1) Waiver As a preliminary matter, “a guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Roney v. United States
W.D.N.C. · 2021 · confidence medium
DISCUSSION (1) Waiver “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Miller v. United States
W.D.N.C. · 2021 · confidence medium
Pre-Plea Assistance “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Harris v. United States
W.D.N.C. · 2021 · confidence medium
Pre-Plea Assistance “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Hanton v. United States
W.D.N.C. · 2021 · confidence medium
No. 6 at 7). “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Broome v. United States
W.D.N.C. · 2021 · confidence medium
A federal prisoner claiming that his “sentence was imposed in violation of the Constitution or the laws of the United States, or that the court was without jurisdiction to impose such sentence, or that the sentence was in excess of the maximum authorized by law, or is otherwise subject to collateral attack, may move the court which imposed the sentence to vacate, set aside or correct the sentence.” 28 U.S.C. § 2255 (a). “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992…
discussed Cited as authority (rule) Rambert-Hairston v. United States
W.D.N.C. · 2021 · confidence medium
DISCUSSION4 (1) Trial Court Error “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Pitchford v. United States
W.D.N.C. · 2021 · confidence medium
The Petitioner’s § 2255 claims were waived by her knowing and voluntary guilty plea. “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Spikes v. United States (2×) also: Cited "see"
W.D.N.C. · 2021 · confidence medium
However, Petitioner’s knowing and voluntary guilty plea to RICO conspiracy “constitute[d] a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Berkley v. United States
W.D.N.C. · 2021 · confidence medium
Petitioner argues that an adequate investigation of the facts would have revealed that the Petitioner was treated unfairly because of his race and that there was no direct evidence—other than the testimony of a cooperating co-Defendant—that Petitioner purchased or possessed a weapon at any time. “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Greene v. United States
W.D.N.C. · 2021 · confidence medium
“A knowing, voluntary, and intelligent guilty plea to an offense conclusively establishes the elements of the offense and the material facts necessary to support the conviction.” United States. v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) McCloud v. United States
W.D.N.C. · 2021 · confidence medium
United States v. Gary, 954 F.3d 194 (4th Cir. 2020), certiorari granted 2021 WL 77245 (Jan. 8, 2021). “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Moore v. United States
W.D.N.C. · 2021 · confidence medium
DISCUSSION “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Godfrey v. United States
W.D.N.C. · 2021 · confidence medium
Petitioner’s knowing and voluntary guilty plea “constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Thompson v. United States (2×) also: Cited "see"
W.D.N.C. · 2020 · confidence medium
DISCUSSION “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993); see United States v. Cotton, 535 U.S. 625, 630-31 (2002) (noting that defects in an indictment are 4 Any arguments or sub-claims not specifically addressed in this Order have been considered and rejected.
discussed Cited as authority (rule) Stitz v. United States (2×) also: Cited "see"
W.D.N.C. · 2020 · confidence medium
DISCUSSION “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
discussed Cited as authority (rule) Browning v. United States (2×) also: Cited "see"
W.D.N.C. · 2020 · confidence medium
DISCUSSION “[A] guilty plea constitutes a waiver of all nonjurisdictional defects, including the right to contest the factual merits of the charges.” United States v. Willis, 992 F.2d 489, 490 (4th Cir. 1993).
Retrieving the full opinion text from the archive…
UNITED STATES of America, Plaintiff-Appellee,
v.
Rahn Kristopher WILLIS, A/K/A Darin Andre Smith, Defendant-Appellant
92-5490.
Court of Appeals for the Fourth Circuit.
Apr 28, 1993.
992 F.2d 489
1993 U.S. App. LEXIS 9829
1993 WL 131910
James B. Craven, III, Durham, NC, argued, for defendant-appellant., Sandra Jane Hairston, Asst. U.S. Atty., Greensboro, NC, argued (Robert H. Ed-munds, Jr., U.S. Atty., of counsel), for plaintiff-appellee.
Murnaghan, Wilkins, Chapman.
Cited by 238 opinions  |  Published

OPINION

WILKINS, Circuit Judge:

Rahn Kristopher Willis pled guilty to possession with the intent to distribute cocaine base, 21 U.S.C.A. § 841(a)(1) (West 1981), and to using or carrying a firearm “during and in relation to ... [a] drug trafficking crime,” 18 U.S.C.A. § 924(c)(1) (West Supp. 1992). Willis appeals his conviction of the firearm charge, contending that an inoperable firearm is not a “firearm” within the meaning of § 924(c)(1), see 18 U.S.C.A. § 921(a)(3) (West 1976), and that the evidence presented as a factual basis for his guilty plea is insufficient to support his con[*490] viction. Because we conclude that Willis’ voluntary and intelligent guilty plea constitutes an admission of all the elements of the firearm offense, and therefore forecloses his right to challenge his conviction on the grounds alleged, we affirm his conviction.

I.

With Willis’ consent, two police officers who were investigating narcotics violations entered his apartment where an open briefcase filled with money was observed. When asked if he possessed any drugs, Willis produced a plastic bag containing cocaine base. A search of his apartment revealed an additional quantity of cocaine base, a .38 caliber handgun with a broken firing pin, and a box of .38 caliber ammunition. [1] Prior to accepting Willis’ plea of guilty, the district court conducted an unexceptionable Rule 11 colloquy. During this proceeding, Willis agreed that the factual summary of evidence presented by the Government was accurate. He did not object to a weapons expert’s report that the handgun could easily be rendered operable by simply replacing the firing pin, nor did he attempt to reserve any issue for review by entering a conditional guilty plea under Federal Rule of Criminal Procedure 11(a)(2). Finally, in response to questions from the court, he admitted to using or car-, rying a firearm during a drug transaction. Willis now claims that the weapon seized was not a firearm by statutory definition nor did he carry or use one.

II.

The principle guiding disposition of this case has been stated by the United States Supreme Court as follows:

A plea of guilty and the ensuing conviction comprehend all of the factual and legal elements necessary to sustain a binding, final judgment of guilt and a lawful sentence. Accordingly, when the judgment of conviction upon a guilty plea has become final and the offender seeks to reopen the proceeding, the inquiry is ordinarily confined to whether the underlying plea was both counseled and voluntary.

United States v. Broce, 488 U.S. 563, 569, 109 S.Ct. 757, 762, 102 L.Ed.2d 927 (1989). A voluntary and intelligent plea of guilty “is an admission of all the elements of a formal criminal charge,” McCarthy v. United States, 394 U.S. 459, 466, 89 S.Ct. 1166, 1171, 22 L.Ed.2d 418 (1969), and constitutes an admission of all “material facts alleged in the charge,” United States v. Johnson, 888 F.2d 1255, 1256 (8th Cir.1989) (quoting United States v. Parker, 874 F.2d 174, 178 (3d Cir. 1989); cf. United States v. Gilliam, 987 F.2d 1009, 1013 & n. 3 (4th Cir.1993)) (although amount of drugs is not an element of this offense, a guilty plea to an indictment charging that defendant is responsible for distributing an amount of drugs establishes that amount for sentencing purposes in the absence of a reservation of the right to dispute the amount). Furthermore, a guilty plea constitutes a waiver of all nonjurisdictional defects, see Parker v. Ross, 470 F.2d 1092, 1093 (4th Cir.1972), including “the right to contest the factual merits of the charges.” United States v. Freed, 688 F.2d 24, 25 (6th Cir.1982).

This circuit has followed these basic and longstanding principles but has not specifically announced adherence to them through a published opinion. We now take the opportunity to do so in order to erase any ambiguity that may have existed. A knowing, voluntary, and intelligent guilty plea to an offense conclusively establishes the elements of the offense and the material facts necessary to support the conviction.

III.

Section 924(c)(1) provides in pertinent part that “[w]hoever, during and in relation to any ... drug trafficking crime ... uses or carries a firearm, shall, in addition to the punishment provided for such ... drug trafficking crime, be sentenced to imprisonment for five years.” Thus, the material elements of this offense are using or carrying a firearm “during and in relation” to a drug trafficking offense. See United States v. Paz, 927 F.2d 176, 179 (4th Cir.1991). Willis pled guilty to an indictment alleging his use and carrying of a firearm in relation to a drug trafficking crime, and he does not challenge the voluntary, knowing, and intelligent[*491] nature of his guilty plea. Willis’ plea of guilty is thus an admission that he is guilty of the “substantive crime” with which he was charged, using or carrying a firearm during or in relation to a drug trafficking crime. See Broce, 488 U.S. at 570, 109 S.Ct. at 763. By pleading guilty, Willis relinquished his right to contest the meaning of “firearm” [2] or to challenge the sufficiency of the evidence presented as a factual basis for his guilty plea. [3] Accordingly, we affirm Willis’ conviction.

AFFIRMED.

1

. Willis does not challenge the legality of his arrest, the seizure of evidence, nor his conviction for possession with the intent to distribute cocaine.

2

. Willis’ guilty plea renders it unnecessary for us to address his stated grounds for appeal. However, were we to do so we would find without merit his claim that an inoperable firearm is not a "firearm” within the meaning of 18 U.S.C.A. § 921(a)(3) (West 1976). Section 921(a)(3) plainly defines a “firearm" as "any weapon ... which ... is designed to or may readily be converted to expel a projectile by the action of an explosive." Further, other courts of appeals that have addressed this issue have held consistently that there is no requirement that a firearm be operable in order to satisfy the definition contained in § 921(a)(3). See, e.g., United States v. York, 830 F.2d 885, 891 (8th Cir.1987), ce rt. denied, 484 U.S. 1074, 108 S.Ct. 1047, 98 L.Ed.2d 1010 (1988); United States v. Buggs, 904 F.2d 1070, 1075 (7th Cir.1990).

3

. Again, although we need not address this claim, it is clear that the evidence presented creates a sufficient factual basis to sustain the plea. In United States v. Brockington, 849 F.2d 872, 876 (4th Cir.1988), we held that a firearm found under the floormat directly under the defendant’s automobile seat was used "in relation” to the drug trafficking offense, noting that "it is enough if the firearm is present for protection and to facilitate the likelihood of success, whether or not it is actually used.” Similarly, in Paz, 927 F.2d at 179, we found that "constructive possession of firearms in relation to a drug transaction is sufficient to establish ‘use,’ ” and that a firearm located under a mattress was "present and accessible.” The drugs, firearm, and money were all present in Willis’ bedroom, the central area of his drug business; and the firearm, although in a dresser drawer, was present and readily accessible. This evidence is clearly sufficient to support Willis’ plea of guilty to using or carrying a firearm "in relation” to a drug trafficking offense.