Rudolph v. United States, No. 21-12828 (11th Cir. 2024)
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In this case, the United States Court of Appeals for the Eleventh Circuit reviewed appeals from Eric Robert Rudolph, who had pled guilty to six federal arson charges and four counts of using a destructive device during a crime of violence in order to avoid the death penalty. As part of his plea deal, Rudolph had waived his rights to appeal his conviction and sentence, and to collaterally attack his sentence in any post-conviction proceeding. Despite this, Rudolph filed two petitions for habeas corpus under 28 U.S.C. § 2255, seeking to vacate several of his sentences. He argued that his convictions for using an explosive during a crime of violence were unlawful in light of new Supreme Court precedent.
The Eleventh Circuit found that Rudolph’s § 2255 motions were, in fact, collateral attacks on his sentences, which his plea agreements did not permit. The court held that § 2255 is a mechanism for attacking sentences, not convictions. The court also rejected Rudolph's argument that his appeal waivers were unenforceable because he hadn't known he was waiving the right to collaterally attack his convictions, pointing out that the waivers explicitly included motions under § 2255. The court further declined to adopt a so-called "miscarriage of justice" exception to the enforceability of appeal waivers, which some other courts have recognized. The court affirmed the district courts' decisions denying Rudolph’s § 2255 motions.
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