United States v. Parrott, No. 18-1094 (8th Cir. 2018)Annotate this Case
The Eighth Circuit affirmed defendant's sentence after she pleaded guilty to possession of identification documents, possession of counterfeit access devices, and possession of access-device-making equipment and aggravated identity theft. The court held that the appeal waiver was ambiguous and must be read against the government and in favor of a defendant's appellate rights. The court held that counsel was not ineffective for failing to raise an argument foreclosed by U.S. v. Thomas, 841 F.3d 760 (8th Cir. 2016) regarding Guidelines Sec. 2B1.1. The court rejected defendant's claim that her attorney was ineffective for failing to encourage her to write a pre-sentencing letter regarding her acceptance of responsibility.