Background
Jared Calhoun pleaded guilty to conspiracy to distribute and possess with intent to distribute methamphetamine. He was sentenced to a prison term of two hundred ten months. Calhoun appealed, arguing that the district court erred by failing to grant a mitigating or minor-role reduction when calculating his guideline range at sentencing.
The court’s reasoning
The court reviewed the validity and scope of the appeal waiver provision in the plea agreement de novo. Sentence-appeal waivers are enforceable if made knowingly and voluntarily. The government showed that Calhoun’s waiver was enforceable because the district court specifically questioned him about the waiver during the Rule eleven colloquy. Calhoun acknowledged that he understood the waiver and voluntarily waived his right to appeal his sentence. The waiver did not apply only in three narrow circumstances, none of which were present here. The court found it manifestly clear from the record that Calhoun understood the full significance of the waiver.
What it means going forward
This decision reinforces that sentence-appeal waivers in plea agreements are strictly enforced when the defendant is properly advised during the plea colloquy. Defendants who sign such waivers generally cannot appeal sentencing errors, including guideline range calculations, unless the waiver’s specific exceptions apply.
Podcast (federal-narrative-summaries): Play in new window | Download