In re United States, No. 21-1318 (6th Cir. 2022)
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At Townsend’s final pretrial conference, the district court expressed its belief that the U.S. Attorney’s Office for the Eastern District of Michigan had recently adopted a policy of offering only plea deals that contain sentencing-appeal and collateral-review waivers. The court stated its disapproval of these types of waivers and its intention to continue rejecting plea agreements that contain them. Later, the parties negotiated a plea agreement in private that limited Townsend’s right to appeal his conviction or sentence. The court responded that it would not accept the agreement. The government and Townsend filed a joint motion asking the court to accept the plea agreement. The court then canceled the plea hearing. Six months later, the court denied the motion and rejected the proposed plea agreement.
The prosecution sought mandamus relief, which was granted by the Sixth Circuit. A district court does not possess unrestrained discretion to reject a plea agreement. It must, among other things, make an individualized assessment of the agreement and predicate its decision on the specific facts and circumstances presented. Because the district court here failed to do that, this is the narrow circumstance in which the district court abused its discretion. The prosecution has a clear and indisputable right to mandamus on this ground.
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