Background
After a police officer stopped a car driven by Nicholas Rogers and found a gun inside, Rogers was indicted for being a felon in possession of a firearm under Section eighteen of the United States Code, Section nine hundred twenty-two, subsection g, paragraph one. He moved to suppress the gun, arguing the officer lacked reasonable suspicion and unlawfully prolonged the stop. The district court denied the motion, and Rogers later pleaded guilty without a plea agreement, receiving a sentence of forty-two months in prison.
The court’s reasoning
The court noted that a guilty plea waives all suppression issues not expressly reserved by a conditional plea. Rogers did not enter a conditional guilty plea and offered no reason to suggest his plea was unknowing or involuntary. He also failed to respond to the government’s assertion that his unconditional plea estopped him from challenging the suppression motion.
a guilty plea waives all suppression issues not expressly reserved by a conditional plea
United States v. Villa-Madrigal, 683 F.3d 924, 926 (8th Cir. 2012)
What it means going forward
Defendants who plead guilty without reserving specific issues in a conditional plea cannot later appeal the denial of a motion to suppress evidence.