Background
Keyon Lewis challenged the constitutionality of a search and the district court’s denial of his motion to suppress the fruits of that search. Both the search and the denial of the motion occurred prior to his unconditional guilty plea. The government requested summary affirmance.
The court’s reasoning
The court noted that a voluntary, unconditional guilty plea waives all nonjurisdictional defects in the proceedings, including the right to appeal the validity of a search. Since Lewis alleged nonjurisdictional defects, he could not raise those issues on appeal after pleading guilty unconditionally. The court found the law clear that there was no substantial question as to the outcome of the case.
a voluntary, unconditional guilty plea waives all nonjurisdictional defects in the proceedings
United States v. Patti, 337 F.3d 1317, 1320 (11th Cir. 2003)
What it means going forward
Defendants who enter unconditional guilty pleas forfeit the right to appeal nonjurisdictional issues, such as search and seizure challenges, even if those issues were raised before the plea.
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