Background
Xavier Boyd pled guilty to three counts of robbery of a United States postal worker and two counts of brandishing a firearm. The district court sentenced him to 255 months of imprisonment followed by four years of supervised release. Boyd appealed, arguing his appeal waiver was unenforceable because the court did not explain the sentence.
The court’s reasoning
The court held that appeal waivers are enforceable if entered into knowingly and voluntarily and if the appeal falls within the waiver’s scope. The written plea agreement explicitly waived the right to appeal sentencing issues other than criminal history. Boyd did not argue the waiver was invalid or that the appeal fell outside its scope. Instead, he claimed enforcement would cause a miscarriage of justice because the district court failed to explain the sentence. The court ruled that this claim was a routine procedural error and an attempt to circumvent the waiver, not a valid miscarriage of justice exception.
When pleading guilty, defendants may choose to waive appellate rights.
United States v. Williams, 81 F.4th 835, 839 (8th Cir. 2023)
What it means going forward
Defendants who sign plea agreements with appeal waivers cannot challenge sentencing errors based on a lack of explanation unless they can prove a narrow miscarriage of justice exception applies.