Background
The defendant, Handrikus Lykein Dontae Webb, pled guilty to distribution of methamphetamine and possession of firearms by a convicted felon. He agreed to a plea waiver limiting his right to appeal, except for claims of ineffective assistance of counsel, prosecutorial misconduct, and future changes in the law. He was sentenced to sixty-four months of imprisonment and three years of supervised release, which included a condition requiring him to pay for substance abuse testing.
The court’s reasoning
The court reviewed the validity of the appeal waiver and found that Webb entered into it knowingly and voluntarily. The challenges raised by counsel regarding the substantive reasonableness of the sentence and the constitutionality of the supervised release condition fell squarely within the scope of the waiver. The court noted that a recent decision did not alter the validity of the condition in this context. Since the waiver was valid and the issues were barred, the court granted the Government’s motion to dismiss.
What it means going forward
Defendants who sign plea agreements waiving appellate rights cannot challenge their sentences or supervised release conditions on direct appeal unless the waiver is invalid or the challenge relies on a subsequent change in the law.