Case Explained: United States of America v. Timothy Michael Knauff

Court: United States Court of Appeals for the Eighth Circuit

Filed: 2026-07-13

The eighth-circuit granted counsel’s motion to withdraw and dismissed the appeal. The court held that the defendant’s valid and enforceable appeal waiver barred review of the issues raised, including alleged errors in the presentence report and challenges to firearm-related Guidelines provisions. Applying the standard set forth in *United States v. Andis*, the court determined the waiver was knowingly and voluntarily entered into and its enforcement would not result in a miscarriage of justice. After conducting an independent review of the record pursuant to *Penson v. Ohio*, the court found no non-frivolous issues outside the scope of the waiver. Consequently, the appeal is dismissed, leaving the district court’s below-Guidelines-range sentence in effect.

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