Background
Aurelio Quintanilla pleaded guilty to transporting child pornography in violation of Section eighteen thousand two hundred fifty-two A subsection A one and subsection B one. In exchange for the dismissal of two related charges, he waived his right to appeal his conviction and sentence, except for claims of ineffective assistance of counsel. The district court imposed a sentence of two hundred forty months imprisonment, a lifetime term of supervised release, and seventeen thousand five hundred dollars in restitution.
The court’s reasoning
The court held that the appellate waiver was knowing and voluntary, foreclosing challenges to the terms of imprisonment and supervised release. Regarding restitution, the court found that the district court conducted the required proximate-cause inquiry under Paroline v. United States by considering the number of images, the defendant’s role in distribution, and victim impact statements. The court concluded that any disagreement with the outcome of that inquiry did not constitute plain error.
The waiver forecloses his challenges to the terms of imprisonment and supervised release. His restitution challenge fares no better: the record shows a completed causation inquiry and, in any event, no plain error.
United States v. Quintanilla, No. 25-20230 (5th Cir. July 7, 2026)
What it means going forward
Defendants who sign plea agreements with appellate waivers cannot challenge their prison terms or supervised release on appeal, even if they claim the district court gave confusing advice about appeal rights. Courts must still conduct a flexible Paroline inquiry for restitution in child pornography cases, but defendants cannot appeal the specific amount unless the court failed to conduct the inquiry at all.