United States v. Pullie — Fourth Circuit affirmed drug and firearm convictions and sentence

Case
United States of America v. Lashawn D. Pullie
Court
U.S. Court of Appeals for the Fourth Circuit
Judge
Gregory (George W. Bush, 2001); WYNN (Barack Obama, 2010); RICHARDSON (Donald Trump, 2018)
Date Decided
August 11, 2026
Docket No.
24-4498
Topics
Appellate Waiver; Guilty Plea; Self-Representation; Criminal Sentencing
Source
Read the full opinion

Background

Lashawn D. Pullie pleaded guilty in the Eastern District of Virginia to drug-trafficking and firearm charges. He chose to represent himself at his sentencing hearing.

Pullie appealed his conviction and sentence. The Fourth Circuit submitted the appeal without oral argument and resolved it in an unpublished per curiam opinion.

The Court’s Holding

The Fourth Circuit held that many of Pullie’s appellate arguments were foreclosed by a valid and enforceable appellate waiver.

After reviewing the record as to the issues not barred by the waiver, the court found no reversible error. It therefore affirmed Pullie’s conviction and sentence.

Key Takeaways

  • A valid and enforceable appellate waiver foreclosed many of Pullie’s arguments.
  • The court found no reversible error in the issues that remained reviewable.
  • The panel affirmed without oral argument in an unpublished, nonprecedential opinion.

Why It Matters

The decision illustrates how an enforceable appellate waiver can substantially narrow the issues available for review after a guilty plea. It also shows that claims falling outside such a waiver still require a showing of reversible error to obtain relief on appeal.

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