Plain-English summary
Court holds some appeal waivers unenforceable when enforcing them would cause a miscarriage of justice
The Court decided that a general appeal waiver in a plea agreement can be unenforceable if enforcing it would produce a miscarriage of justice — that is, leave a clear, egregious error uncorrected. The case was vacated and remanded to the lower court for further proceedings.
Why this matters
This decision affects how strictly courts will enforce plea-agreement appeal waivers. Defendants cannot be automatically barred from all appeals just because they signed a broad waiver; if enforcing a waiver would allow a glaring injustice to stand, courts may refuse to enforce the waiver and allow an appeal. That preserves a safety valve to correct serious sentencing or procedural errors that otherwise would go unreviewed.
Who may feel it
- People who pleaded guilty and signed appeal waivers in federal criminal cases
- Defense attorneys negotiating plea agreements
- Prosecutors who use plea agreements with waiver provisions
- Federal trial and appellate judges who must decide waiver enforceability
Key questions