4th Cir.

United States v. Mitchell McNeil

April 27, 2026 ·25-4224 ·Per Curiam · By James Taylor

The Fourth Circuit affirmed a three hundred month sentence for drug distribution offenses. The court held that the government did not breach the plea agreement by seeking a dangerous weapons enhancement.

Background

Mitchell McNeil pled guilty to drug distribution offenses involving methamphetamine and marijuana. He received a three hundred month sentence. He appealed, claiming the government breached the plea agreement by seeking a dangerous weapons enhancement.

The court’s reasoning

The court applied plain error review because the appellant did not challenge the government’s action in the district court. The court held that plea agreements are contracts and the government is only bound by promises explicitly made. The agreement reserved the government’s right to present evidence and did not limit arguments on sentencing factors not stipulated.

Because McNeil did not challenge the government’s purported breach of the plea agreement before the district court, we review his claim for plain error.

United States v. Edgell, 914 F.3d 281, 286 (4th Cir. 2019)

What it means going forward

The ruling clarifies that plea agreements do not implicitly bar the government from arguing for sentencing enhancements unless the agreement explicitly limits such arguments.