Case Explained: USA V. CELAYA

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-16

Docket: 2:21-cr-00225-TLN-1

The Ninth Circuit dismissed Jesus Celaya’s appeal of his 73-month sentence for distributing methamphetamine because he waived his right to appeal under the terms of his plea agreement. The court applied a de novo standard of review to determine if the waiver was enforceable, finding that it was valid because the agreement’s language encompassed the specific grounds raised by Celaya and was entered into knowingly and voluntarily during the change-of-plea hearing. Although Celaya argued that an appeal waiver should be unenforceable due to a “miscarriage of justice,” the court held that under *Hunter v. United States*, standard errors in misapplying sentencing law do not constitute such an error sufficient to override a valid waiver. As a result, the court enforced the waiver and dismissed the appeal without addressing the merits of Celaya’s objection regarding the base offense level calculation.

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