Background
Mitchell McNeil pled guilty to drug distribution offenses involving methamphetamine and marijuana. He received a three hundred month sentence. He appealed, claiming the government breached the plea agreement by seeking a dangerous weapons enhancement.
The court’s reasoning
The court applied plain error review because the appellant did not challenge the government’s action in the district court. The court held that plea agreements are contracts and the government is only bound by promises explicitly made. The agreement reserved the government’s right to present evidence and did not limit arguments on sentencing factors not stipulated.
Because McNeil did not challenge the government’s purported breach of the plea agreement before the district court, we review his claim for plain error.
United States v. Edgell, 914 F.3d 281, 286 (4th Cir. 2019)
What it means going forward
The ruling clarifies that plea agreements do not implicitly bar the government from arguing for sentencing enhancements unless the agreement explicitly limits such arguments.