United States v. Padgett, No. 16-16144 (11th Cir. 2019)
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Defendant purported to bring a direct criminal appeal, alleging that the government breached the terms of their plea agreement. After sentencing, defendant filed an untitled document in the district court stating her intent to file a collateral attack.
The Eleventh Circuit dismissed the appeal based on lack of jurisdiction. The court held that defendant's filing reflected her understanding of her waiver of a direct appeal under the plea agreement, and the filing did not comply with the jurisdictional requirements for a notice of appeal under Rule 3 of the Federal Rules of Appellate Procedure.
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