Devin Chaney v. United States

Although the right to appeal a criminal sentence is a statutory entitlement, federal prosecutors in many jurisdictions—including the Eastern District of Louisiana—require plea agreements containing a waiver of that right. At the point a criminal defendant enters into such an agreement, however, he has no way of knowing what errors the district court may commit at a future sentencing hearing nor the magnitude and impact of such errors. This Court has yet to rule on the validity of such waivers nor the limits on their enforcement. The result is a messy, multidimensional circuit split that injects confusion, unpredictability, and disparate treatment into one of the most common procedures in federal criminal law: the plea agreement. In this case, Petitioner Devin Chaney signed such an agreement without knowing (or possibly being able to anticipate) that the district court would eschew its basic duties and responsibilities at sentencing—not just failing to correct error brought to its attention but refusing to address the issue at all. As a result, Mr. Chaney received a sentence six years higher than he should have, following a sentencing proceeding that did not comport with basic tenants of due process. Thus, the questions presented are: Can a criminal defendant knowingly and voluntarily waive the right to appeal a district court’s yet-to-be-made errors as part of a plea agreement, and, if so, what are the limits on the validity and enforceability of such appeal waivers? Relatedly, did the appeal waiver in Mr. Chaney’s case qualify for the so-called “miscarriage of justice” or other exception recognized by numerous appellate courts?