United States v. Eric Goodall, 15 F.4th 987

Goodall and two associates committed a string of armed robberies in Las Vegas; Goodall personally brandished a TEC-9 in multiple robberies.
A grand jury charged Goodall with two Hobbs Act conspiracy counts and two § 924(c) counts; he pleaded guilty to two conspiracy counts and one § 924(c) count.
As part of the plea, Goodall agreed to a 240-month (20-year) recommended sentence and a broad waiver of appellate and collateral challenges (except ineffective assistance and certain upward departures).
The district court rejected the 240-month recommendation and sentenced Goodall to 168 months (84 months for the conspiracies and 84 months for the § 924(c) conviction).
After sentencing, the Supreme Court decided United States v. Davis, holding § 924(c)’s residual clause unconstitutional; Goodall appealed to vacate his § 924(c) conviction based on Davis and argued his appellate waiver did not cover unforeseen legal developments and that the court should extend the “illegal sentence” exception to cover “illegal convictions.”
The Ninth Circuit enforced the appellate waiver, held the waiver was knowing and voluntary (defendant assumed the risk of future changes in law), and declined to expand the “illegal sentence” exception to permit vacatur of convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Goodall's broad appellate waiver bars his Davis-based challenge to the § 924(c) conviction	Waiver cannot bar an appeal based on a legal claim that did not exist when the plea was entered	Waiver language covers any aspect of conviction or sentence, including later-arising claims	Waiver bars the appeal; its plain language encompasses Goodall's Davis challenge
Whether the waiver was knowing and voluntary given subsequent changes in law (Johnson/Davis)	Defendant could not knowingly waive rights to claims that were unforeseeable at plea time	A defendant assumes the risk that law may change; plea waivers remain valid despite later legal developments	Waiver was knowing and voluntary; later changes in law do not invalidate a valid waiver
Whether the Ninth Circuit should extend the “illegal sentence” exception to appellate waivers so it applies to convictions rendered unlawful by later decisions	The Torres “illegal sentence” exception should be expanded to allow challenge to an “illegal conviction”	Torres was limited to sentences; convictions are known at plea time and do not implicate the same uncertainty	Court declined to expand Torres; the “illegal sentence” doctrine does not cover post-plea claims of “illegal convictions”

United States v. Davis, 139 S. Ct. 2319 (2019) (held § 924(c)’s residual clause unconstitutional)
Johnson v. United States, 576 U.S. 591 (2015) (held residual clause in ACCA unconstitutionally vague)
United States v. Torres, 828 F.3d 1113 (9th Cir. 2016) (refused to enforce waiver as to an illegal sentence under Guidelines vagueness)
United States v. Jeronimo, 398 F.3d 1149 (9th Cir. 2005) (enforceability standard for appellate waivers)
United States v. Navarro-Botello, 912 F.2d 318 (9th Cir. 1990) (waiver remains valid despite unforeseeable future issues)
Oliver v. United States, 951 F.3d 841 (7th Cir. 2020) (enforced plea waivers against later § 924(c) challenges; defendants assume risk of future legal changes)
Town of Newton v. Rumery, 480 U.S. 386 (1987) (certainty of negotiated pleas outweighs speculative future benefits)
Blackledge v. Allison, 431 U.S. 63 (1977) (principles supporting finality of guilty pleas)