United States v. Rashaun Williams, No. 22-2782 (8th Cir. 2023)
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Defendant was indicted on three counts of drug possession with intent to distribute. On the morning of the trial, he decided to plead guilty to two of them in exchange for dismissal of the third. The district court performed the usual change-of-plea colloquy. Defendant said that his mind was “crystal clear” and that he was not on any medications or drugs. Yet some of his responses showed hesitation. He said he had little time to go over the plea agreement with his lawyer and felt rushed. On top of that, he regretted not taking an earlier plea offer made while his mother’s recent death weighed heavily on him. Still, the court found Defendant competent to proceed with his proposed plea and confirmed that he was satisfied with his attorney. On appeal, Defendant argued that the district court violated his Sixth Amendment right to counsel at sentencing when it allowed his lawyer to withdraw, neglected to appoint another one, and failed to warn Defendant about the risks of proceeding on his own.
The Eighth Circuit dismissed his appeal, finding that Defendant waived his right to challenge these issues. The court explained that recognizing the validity of appeal waivers provides defendants with an important bargaining chip. The court wrote that applying the miscarriage-of-justice exception here would weaken that presumption of validity and reduce Defendant's bargaining power. As such, the court found that in this case, there is a valid appeal waiver and no showing that a miscarriage of justice would result from its enforcement.
Court Description: [Gruender, Author, with Arnold and Kelly, Circuit Judges] Criminal case - Criminal law. Defendant's appeal issues fall within the scope of the appeal waiver in his knowing and voluntary plea agreement; claims that enforcing the appeal waiver would result in a miscarriage of justice rejected. Judge Kelly, dissenting.
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