Background
Aaron Thompson pleaded guilty to two counts of mailing threatening communications in violation of federal law. He received a forty-one-month sentence and agreed to a plea deal that included a waiver of his right to appeal the sentence. Later, Thompson filed a notice of appeal challenging the sentence as unreasonable.
The court’s reasoning
The court reviewed the validity of the appeal waiver provision. It found that the waiver was made knowingly and voluntarily during the change-of-plea hearing. The court noted that the right to appeal is statutory and that waivers must be given full effect. Since none of the exceptions in the waiver applied, the appeal was barred.
What it means going forward
Defendants who sign plea agreements with appeal waivers must ensure their sentences fall within the agreed-upon exceptions to challenge them later.
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