United States v. Adam Clodfelter, 24-4374

Adam Michael Clodfelter pled guilty to possession with intent to distribute methamphetamine, in violation of 21 U.S.C. § 841(a)(1), (b)(1)(C), under a plea agreement.
The district court sentenced Clodfelter to 151 months’ imprisonment.
Clodfelter, through counsel, appealed, raising issues regarding the reasonableness of his sentence, and filed a pro se brief challenging his career offender status and alleging ineffective assistance of counsel.
The Government moved to dismiss based on an appeal waiver in Clodfelter’s plea agreement, contending the waiver precluded the appellate claims.
The court reviewed whether the waiver was valid and if any claims fell outside the waiver’s scope, especially ineffective assistance of counsel.
The court ultimately reviewed the record under Anders v. California for any non-frivolous grounds for appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of Appeal Waiver	Waiver was not knowing/voluntary	Waiver was valid and enforceable	Waiver was knowing, voluntary, and enforceable
Reasonableness of Sentence	Sentence not reasonable (Anders)	Sentence falls within plea waiver scope	Dismissed; issue barred by valid waiver
Career Offender Designation	Wrongly designated as career offender	Falls within scope of the waiver	Dismissed; issue barred by valid waiver
Ineffective Assistance of Counsel	Ineffective assistance at trial	Not properly before court on direct appeal	Not cognizable on direct appeal; not conclusive

United States v. Adams, 814 F.3d 178 (4th Cir. 2016) (validity and enforceability of appeal waivers)
United States v. McCoy, 895 F.3d 358 (4th Cir. 2018) (standard for knowing and voluntary waivers)
United States v. Freeman, 24 F.4th 320 (4th Cir. 2022) (ineffective assistance claims not established on direct appeal)
United States v. Faulls, 821 F.3d 502 (4th Cir. 2016) (ineffective assistance claims should be raised in § 2255 motions)