Background
Chauncey White pleaded guilty to two counts of sexual abuse of a minor in violation of federal statutes. The district court sentenced him to a total term of imprisonment of three hundred twenty months to run consecutively with a thirty-two-month sentence from another case. White appealed, arguing the district court miscalculated the sentencing guidelines range and imposed an unreasonable sentence.
The court’s reasoning
The court reviewed the validity of the appeal waiver de novo. It found that White’s appeal fell within the scope of the waiver and that he entered the waiver knowingly and voluntarily. The district court had informed White that he preserved his right to appeal only for ineffective assistance of counsel or if the sentence exceeded the advisory guidelines range. White acknowledged he understood these terms. The court concluded there was no miscarriage of justice to override the waiver.
We review the validity and applicability of an appeal waiver de novo.
United States v. Williams, 81 F.4th 835, 839 (8th Cir. 2023)
What it means going forward
Defendants who sign plea agreements waiving appeal rights for sentences within or below the guidelines range cannot challenge those sentences on appeal unless they can prove a miscarriage of justice.