Background
Ray Cozart, Jr. pled guilty to conspiracy to distribute fentanyl and methamphetamine in violation of federal statutes. The district court imposed a sentence of one hundred forty-four months imprisonment, varying below the advisory Sentencing Guidelines range. Cozart appealed, with counsel filing a brief under Anders v. California stating no meritorious grounds for appeal existed but questioning the plea validity and sentence reasonableness. The Government moved to dismiss the appeal based on an appeal waiver in the plea agreement.
The court’s reasoning
The court reviewed the validity of the guilty plea for plain error, finding it was knowing, voluntary, and supported by an adequate factual basis. The court then reviewed the appeal waiver de novo, determining it was valid and that the challenge to sentence reasonableness fell within its scope. The court found no meritorious grounds for appeal outside the waiver’s scope and granted the Government’s motion to dismiss in part.
What it means going forward
Defendants who sign plea agreements with appeal waivers cannot challenge the reasonableness of their sentences on appeal, even if they raise other issues, unless they can show the plea itself was invalid.