Background
Jaimon Tywan Hannah pleaded guilty to Hobbs Act robbery in violation of Section eighteen five one of Title eighteen of the United States Code. The district court sentenced him to one hundred thirty-two months of imprisonment and three years of supervised release. On appeal, Hannah’s counsel filed a brief pursuant to Anders v. California, questioning the validity of the guilty plea and the reasonableness of the sentence. The Government moved to dismiss the appeal based on Hannah’s plea agreement waiver.
The court’s reasoning
The court concluded that Hannah knowingly and voluntarily agreed to waive his right to appeal. The district court’s statement advising Hannah of the timeline for filing a notice of appeal did not affect the validity of the waiver. The court reviewed the entire record for potentially meritorious issues under Anders and found none. The court determined that the district court conducted a thorough Rule eleven hearing and that the record showed no plain error affecting Hannah’s substantial rights.
To determine whether a defendant knowingly and voluntarily agreed to waive his appellate rights, we look to the totality of the circumstances, including the defendant’s experience, conduct, educational background and knowledge of his plea agreement and its terms.
United States v. Carter, 87 F.4th 217, 224 (4th Cir. 2023)
What it means going forward
The decision reinforces the enforceability of appeal waivers in plea agreements when the defendant has been properly advised during the Rule eleven colloquy. It also clarifies the court’s obligation to conduct a full Anders review even when an appeal waiver is in place.
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