Elijah Muhammad v. United States

The overwhelming majority of criminal cases are resolved by plea bargaining. However, how these agreements are interpreted lacks uniformity in the federal appellate courts. In this case concerning a breach of a plea agreement, the court of appeals strictly limited its review to the “four corners” of the agreement. This approach departs from those of other courts of appeals who do not so limit their review of the plea agreement and instead consider the parties’ conduct and expectations. The questions presented are:

1. Whether a court should only look at the “four corners” of the plea agreement language when determining whether a breach of the plea agreement occurred; as opposed to also looking at circumstances and events outside of the four corners that are relevant to the reasonable understanding and expectations of the agreement?

2. Weather the Fifth Circuit’s newly established “four corners” doctrine, led to a deprivation of due process of the Petitioner because a reasonable person in his position would have thought the plea agreement for his drug case covered his conduct surrounding a sex trafficking case?