Background
Aaron Thompson, a Florida prisoner serving a thirty-year sentence, mailed threatening letters to judges in 2022. He pleaded guilty to two counts of mailing threatening communications in violation of Section eighteen United States Code Section eight seven six C. The plea agreement included a waiver of his right to appeal his sentence unless specific exceptions applied, such as the sentence exceeding the guideline range or violating the Eighth Amendment. He received a forty-one-month sentence followed by three years of supervised release.
The court’s reasoning
The court reviewed the validity of the appeal waiver provision de novo. It found that the waiver was enforceable because Thompson knowingly and voluntarily pleaded guilty. The record showed that a magistrate judge specifically questioned Thompson about the waiver during the change-of-plea hearing. The court rejected Thompson’s argument that such waivers are unconstitutional, noting that the right to appeal is statutory. Since none of the exceptions in the waiver applied to his case, the appeal was barred.
What it means going forward
Defendants in the Eleventh Circuit who sign plea agreements with sentence appeal waivers cannot challenge their sentences on appeal unless the specific exceptions in the waiver are met.
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