Background
The defendant, Uriel Mendoza Plancarte, appealed a criminal judgment from the United States District Court for the Northern District of Georgia. The Government moved to dismiss the appeal based on an appeal waiver included in the defendant’s plea agreement.
The court’s reasoning
The court held that sentence appeal waivers are enforced if they were made knowingly and voluntarily. The court cited precedent establishing that such waivers clearly convey to the defendant that they are giving up their right to appeal under most circumstances. The waiver extends to difficult or debatable legal issues and even blatant error.
it was clearly conveyed to the defendant that he was giving up his right to appeal under most circumstances
United States v. Boyd, 975 F.3d 1185, 1192 (11th Cir. 2020)
What it means going forward
Defendants who sign plea agreements with appeal waivers cannot challenge their sentences on appeal unless they can prove the waiver was not made knowingly and voluntarily.