United States v. Angel – Do It For The Caselaw

Holding: The court dismissed the appeal because the defendant's sentence appeal waiver was valid and none of the waiver's exceptions applied to his claim.
Standard: De novo review of sentence appeal waiver validity
Vote: Per Curiam decision dismissing the appeal.
Practical effect: Defendants who sign plea agreements with sentence appeal waivers cannot challenge the reasonableness of their sentences on appeal unless the sentence involves an upward departure, the government appeals, or there is a claim of ineffective assistance of counsel.

The United States Court of Appeals for the Eleventh Circuit dismissed an appeal challenging the reasonableness of a below-guideline sentence. The court held that the defendant had knowingly and voluntarily waived his right to appeal in his plea agreement.

Background

Christopher Justin Angel appealed his forty-eight-month sentence for possession of child pornography, arguing the sentence was unreasonable. The government moved to dismiss the appeal, citing a sentence appeal waiver in Angel’s plea agreement.

The court’s reasoning

The court reviewed the validity of the sentence appeal waiver de novo. It found that the waiver was made knowingly and voluntarily because the plea agreement contained specific language waiving the right to appeal, Angel acknowledged understanding the waiver with his attorney, and the district court explained the waiver’s terms during the plea colloquy and sentencing hearing. The court noted that the exceptions to the waiver did not apply because the sentence was not an upward departure or variance, the government did not initiate an appeal, and Angel did not allege ineffective assistance of counsel.

To the maximum extent permitted by federal law, the Defendant voluntarily and expressly waives the right to appeal his conviction and sentence and the right to collaterally attack his conviction and sentence in any post-conviction proceeding

United States v. Angel, 25-13383 (11th Cir. 2026)

What it means going forward

Defendants who sign plea agreements with sentence appeal waivers cannot challenge the reasonableness of their sentences on appeal unless the sentence involves an upward departure, the government appeals, or there is a claim of ineffective assistance of counsel.

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