US v. Taylor-Sanders, No. 20-4604 (4th Cir. 2023)
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In the United States Court of Appeals for the Fourth Circuit, the case involved defendant Glenda Taylor-Sanders, a licensed insurance agent, who pleaded guilty to one count of wire fraud. Taylor-Sanders had used her position to defraud several trucking companies and an insurance finance company, BankDirect Capital Finance, by misappropriating funds meant for insurance premiums and obtaining loans under the guise of non-existent insurance policies. She used the funds for personal expenditures, leading to the lapse of some of the trucking companies' insurance policies.
In her plea agreement, Taylor-Sanders agreed to pay full restitution to all victims harmed by her relevant conduct, and she waived all rights to contest the conviction and sentence in any appeal, unless it was due to ineffective assistance of counsel or prosecutorial misconduct. However, she later attempted to withdraw her guilty plea, arguing that she didn't fully understand the implications of her plea and that she never acted with the requisite intent to defraud. The district court denied her motion to withdraw the plea, concluding that her claim was not credible and that she had not provided a fair and just reason to withdraw her guilty plea.
After being sentenced to 66 months' imprisonment and ordered to pay over $700,000 in restitution, Taylor-Sanders appealed her conviction, sentence, and the restitution order. She argued that her guilty plea wasn’t knowing and voluntary, that the district court miscalculated her offense level, and that the district court made several errors when awarding restitution.
The Court of Appeals found that Taylor-Sanders's guilty plea and plea waiver were valid and the issues she raised on appeal fell within the scope of her appeal waiver. The court distinguished between claims that a sentence is "illegal" because the district court lacked the authority to issue the sentence (which remain reviewable despite an appeal waiver) and claims that a sentence was "imposed in violation of law" because it has otherwise merely "been touched by a legal error" (in which case the court will enforce the appeal waiver). The court dismissed Taylor-Sanders's appeal in its entirety.
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