Malyk Jajuan Ransburg pleaded guilty to being a felon in possession of ammunition and a firearm, and possession of methamphetamine with intent to distribute. He was sentenced to 324 months in prison. Following his sentencing, Ransburg attempted to appeal his sentence, but the government moved to enforce the appeal waiver contained in his plea agreement. Ransburg argued that the government breached the agreement by failing to support a downward sentencing adjustment for acceptance of responsibility and that the waiver should not be enforced because it would result in a miscarriage of justice.
The court applied the two-part test from United States v. Hahn to determine if the appeal waiver was enforceable: whether the appeal falls within the scope of the waiver and whether enforcement would result in a miscarriage of justice. First, regarding the scope, the court analyzed whether the government breached the plea agreement. The agreement stated that Ransburg would receive a two-level downward adjustment for acceptance of responsibility only if he did not falsely deny or frivolously contest relevant conduct. The district court found that Ransburg did falsely deny relevant conduct during his sentencing testimony. Consequently, the court held that the government was under no obligation to request the adjustment, and there was no breach of the agreement. The court noted that the plea agreement also explicitly stated the court was not bound by the agreement's recommendations. Second, regarding the miscarriage of justice exception, the court explained that this exception applies only in narrow circumstances, such as if the sentence exceeds the statutory maximum or if the waiver itself is unlawful. Ransburg argued that enforcing the waiver would be unlawful, but the court clarified that his challenge focused on sentencing decisions, not the lawfulness of the waiver itself. The court concluded that Ransburg failed to meet his burden to demonstrate that the waiver resulted in a miscarriage of justice.
The appeal is dismissed, leaving the 324-month sentence in place. The decision reinforces that plea agreement waivers are strictly enforced when a defendant's conduct, such as falsely denying relevant facts, disqualifies them from specific sentencing benefits. It clarifies that challenges to the district court's sentencing decisions do not automatically trigger the miscarriage of justice exception to an appeal waiver.
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