4th Cir.

United States v. King

May 4, 2026 ·24-4227 ·Per Curiam · By James Taylor

The United States Court of Appeals for the Fourth Circuit dismissed an appeal by a defendant challenging his firearm possession sentence. The court held that the defendant's valid appeal waiver in his plea agreement barred his claims of procedural and substantive unreasonableness.

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Background

Jordale King pleaded guilty to possession of a firearm and ammunition by a felon in violation of Section eighteen of the United States Code, Section nine hundred twenty-two, subsection G, paragraph one. The district court sentenced him to ninety-six months of imprisonment and three years of supervised release. King appealed, arguing the sentence was unreasonable and that the court improperly rejected his plea agreement type.

The court’s reasoning

The court reviewed the validity of the appeal waiver de novo. It found that the record showed King knowingly and intelligently waived his rights to appeal. The court noted that the district court’s policy of rejecting Rule eleven, subsection C, plea agreements did not affect King’s decision to plead guilty under a Rule eleven, subsection B agreement. Consequently, the waiver was valid and the sentencing challenges fell within its scope.

What it means going forward

This decision reinforces that appeal waivers in plea agreements are enforceable when entered into knowingly and voluntarily, even if the defendant later disputes the specific type of plea agreement offered or the sentence imposed.

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