United States v. Francisco Fuentes, 2017 U.S. App. LEXIS 10230

Fuentes was charged with illegal reentry under 8 U.S.C. §§ 1326(a) and (b)(2); he pleaded guilty pursuant to a written plea agreement.
The plea agreement and presentence report (PSR) applied an 8-level enhancement under U.S.S.G. § 2L1.2(b)(1)(C) because of a prior burglary conviction classified as an "aggravated felony."
The parties agreed to a 3-level reduction for acceptance of responsibility, yielding an advisory Guidelines range of 24–30 months.
At the change-of-plea and sentencing hearings, the court explained the enhancement and Fuentes repeatedly confirmed he understood and agreed with the calculations.
Fuentes’s sentencing memorandum expressly stated he agreed with the PSR calculations, including that his prior burglary qualified as an aggravated felony.
At sentencing Fuentes objected to one factual PSR point (which the court corrected) but did not object to the base offense level or the 8-level enhancement; the court sentenced him to 24 months.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Fuentes may challenge the 8-level aggravated-felony enhancement on appeal	Fuentes contends the prior burglary was not an aggravated felony and the enhancement was applied in error	Government argues Fuentes waived the challenge by agreeing to the enhancement in plea agreement and at hearings	Waived: appellate review precluded because Fuentes intentionally relinquished the right to contest the Guidelines range

United States v. Brodie, 507 F.3d 527 (7th Cir. 2007) (distinguishes waiver from forfeiture; intentional relinquishment precludes review)
United States v. Armour, 804 F.3d 859 (7th Cir. 2015) (finding waiver where defendant objected to some PSR matters but not applicable Guidelines range)