What is the current state of the law on challenging a guilty plea?

Additionally, where, as here, "an appellant has not requested that counsel challenge the validity of a plea or has not made such a challenge in a pro se brief, an Anders brief should either: (i) state that counsel, having considered the possible benefits and risks, believes that appellant would run an unacceptable risk of adverse consequences in challenging the validity of a plea, or (ii) discuss the validity of the plea and why there are no non-frivolous issues regarding the plea on which to base an appeal." United States v. Ibrahim, 62 F.3d 72, 74 (2d Cir. 1995). But "[t]he representation . . . concerning the risks of challenging a guilty plea need not be explicitly articulated where those risks are fairly inferable from counsel's report of the sentence and the circumstances under which it was imposed," which "inference will often be available where a plea was entered pursuant to a plea or sentence bargain or a cooperation agreement." United States v. Bygrave, 97 F.3d 708, 709 (2d Cir. 2006).