United States v. Cameron Washington, 695 F. App'x 689

Cameron Washington pled guilty under a Rule 11(c)(1)(C) plea agreement to conspiracy to distribute and possess with intent to distribute cocaine base; the agreement specified a sentencing range of 84–144 months.
The district court sentenced Washington to 100 months.
Paragraph 10 of the plea agreement reserved the parties’ right to present all relevant information at sentencing, including conduct underlying dismissed counts.
After Washington signed his plea, the U.S. Sentencing Commission issued an August 2016 report affecting career‑offender analysis and the sentencing of two codefendants who signed pleas after the report.
Washington argued on appeal that the Government breached the plea agreement by not calling the Commission report to the court’s attention and that, but for that omission, he would have received the 84‑month sentence his codefendants received.
Washington also challenged the procedural reasonableness of his sentence, but the Government sought enforcement of his appellate‑waiver in the plea agreement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Government breached the plea agreement by failing to present the Sentencing Commission report at sentencing	Washington: the Gov't failed to bring the Commission's August 2016 report (affecting career‑offender analysis) to the court’s attention, depriving him of a lower (84‑month) sentence	Gov't: plea required only that parties could present relevant information; there was no obligation to present the Commission report or to request a specific 84‑month sentence	No breach; plea did not obligate the Government to present the report or seek 84 months, and 100 months falls within the agreed 84–144 month range
Whether Washington may appeal the procedural reasonableness of his sentence despite an appellate waiver in the plea agreement	Washington: sentence was procedurally unreasonable	Gov't: appellate waiver was knowing and valid; the procedural‑reasonableness claim falls within the scope of the waiver	Appeal waiver valid and enforceable; the procedural‑reasonableness challenge is barred by the waiver

Santobello v. New York, 404 U.S. 257 (1971) (prosecutor promises that induce guilty pleas must be fulfilled)
Olano v. United States, 507 U.S. 725 (1993) (plain‑error review framework)
McLaughlin v. United States, 813 F.3d 202 (4th Cir. 2016) (plea‑agreement interpretation follows contract principles)
Blick v. United States, 408 F.3d 162 (4th Cir. 2005) (standards for enforcing appellate waivers)
Johnson v. United States, 410 F.3d 137 (4th Cir. 2005) (on when a waiver is knowing and enforceable)