8th Cir.

United States of America v. Darnell L. Clemons

July 21, 2026 ·25-2333 ·Panel Decision ·Per Curiam · By James Taylor

The Eighth Circuit enforced an appeal waiver in a criminal case where the defendant raised pro se claims of ineffective assistance and misconduct.

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Background

Darnell Clemons pleaded guilty to carjacking, ammunition, and firearms offenses under a plea agreement containing an appeal waiver. He appealed despite the waiver, and his counsel moved to withdraw under Anders versus California.

The court’s reasoning

The court found Clemons understood the waiver terms at his plea hearing. Ineffective assistance claims belong in collateral review. Sentencing and misconduct claims were waived. No miscarriage of justice would result from enforcement.

we will enforce the appeal waiver

What it means going forward

Appeal dismissed and counsel withdrawn.