Case Explained: USA V. OWENS

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-06-24

Docket: 1:23-cr-00045-LEK-1

The ninth-circuit dismissed the consolidated appeals filed by Seth Zachary Owens challenging his guilty-plea convictions for being a felon in possession of ammunition and obstruction of justice, as well as his concurrent 33-month sentences. The court held that the appeals were barred because Owens had waived his right to appeal through enforceable plea agreements. In reaching this decision, the court conducted an independent review of the record pursuant to *Penson v. Ohio* and applied the standard for enforcing appeal waivers established in *United States v. Watson*, concluding that no non-frivolous issues existed regarding the enforceability of those waivers. As a practical consequence, the appeals were dismissed, and counsel’s motion to withdraw under *Anders v. California* was granted.

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