Background
Aaron Thompson, a Florida prisoner serving a thirty-year sentence, mailed letters to judges threatening to kill them and their families. He was charged with mailing interstate threats and pleaded guilty to two counts in exchange for the dismissal of a third count. The plea agreement included a provision waiving his right to appeal his sentence unless specific exceptions applied. The district court imposed a forty-one-month sentence followed by three years of supervised release. Thompson later filed a notice of appeal challenging the sentence as substantively unreasonable.
The court’s reasoning
The court reviewed the validity of the appeal waiver provision de novo. It found that the waiver was enforceable because the defendant knowingly and voluntarily pleaded guilty. The magistrate judge had specifically questioned Thompson about the waiver during the change-of-plea hearing, and Thompson indicated he understood he was giving up his right to appeal. The court noted that the right to appeal is statutory, not constitutional, and that knowing and voluntary waivers must be given full effect. Since none of the exceptions in the waiver applied, the appeal was barred.
What it means going forward
This decision reinforces the enforceability of sentence appeal waivers in plea agreements within the Eleventh Circuit, provided the waiver was entered into knowingly and voluntarily.
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