United States of America v. Timothy Michael Knauff
July 13, 2026·26-1087·Panel Decision·By James Taylor
The Eighth Circuit granted counsel leave to withdraw and dismissed the appeal in a drug sentencing case. The court found the defendant's appeal waiver valid and enforceable, concluding there were no non-frivolous issues outside its scope.
Timothy Knauff appealed a below-Guidelines-range sentence imposed after he pleaded guilty to a drug offense. His counsel moved to withdraw, filing a brief under Anders v. California, arguing errors in the presentence report and the constitutionality of firearm-related Guidelines provisions.
The court’s reasoning
The court concluded that the appeal waiver was valid, enforceable, and applicable to the issues raised. After independently reviewing the record pursuant to Penson v. Ohio, the court found no non-frivolous issues for appeal outside the scope of the waiver.
What it means going forward
The appeal is dismissed, and counsel is relieved of representation, leaving the district court’s sentence in place.
