Background
Deangelo Gene Williams pleaded guilty to a drug offense in the U.S. District Court for the District of Minnesota. His written plea agreement included a waiver of his right to appeal.
Williams nevertheless appealed the sentence imposed by District Judge David S. Doty. Williams’s counsel filed an Anders brief, sought permission to withdraw, and challenged the sentence.
The Court’s Holding
The Eighth Circuit concluded that Williams’s appeal waiver was valid and enforceable and that the sentencing issue raised on appeal fell within the waiver’s scope. The court determined that the waiver satisfied the governing requirements for enforcement, including that Williams entered it knowingly and voluntarily and that enforcement would not cause a miscarriage of justice.
After independently reviewing the record under Penson v. Ohio, the court found no nonfrivolous appellate issues outside the waiver’s scope. It therefore granted counsel leave to withdraw and dismissed the appeal.
Key Takeaways
- A knowing and voluntary appeal waiver generally bars sentencing challenges that fall within its scope.
- The Eighth Circuit found no miscarriage-of-justice basis for declining to enforce Williams’s waiver.
- The court’s independent record review revealed no nonfrivolous issue outside the waiver, so it allowed counsel to withdraw and dismissed the appeal.
Why It Matters
The unpublished decision reinforces that defendants who enter written plea agreements containing valid appeal waivers ordinarily cannot obtain appellate review of covered sentencing claims. An Anders filing does not avoid the waiver, although the appellate court still independently examines the record for nonfrivolous issues that remain appealable.