United States v. Haslam, 833 F.3d 840

Haslam pleaded guilty under a written plea agreement to counts involving manufacturing methamphetamine, unregistered silencers, and possessing a firearm in furtherance of a drug offense.
The presentence report included as relevant conduct an incident where Haslam held a woman hostage under the mistaken belief she was an undercover officer.
Haslam argued the government breached the plea agreement by informing probation and the court about the hostage incident, moving to withdraw his pleas.
The district court denied the motion and imposed a sentence of 181 months; Haslam appealed challenging the denial.
The plea agreement reserved the government’s right to inform the court of the offense and Haslam’s background; Haslam claimed this implied limits on disclosure were breached.
At sentencing, the Sample incident was testified to and discussed despite its prior removal from the factual basis, prompting further briefing on potential breach.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the government breached the plea by informing the court about Sample	Haslam claims breach due to implied promise.	Government asserts no promise restricting disclosure; agreement reserves right to inform court.	No breach; contract unambiguous and permits full informing of the court.
Whether Haslam knowingly entered the plea	Haslam believed the Sample incident was off-limits due to an implied promise.	Sworn colloquy showed understanding and no extrinsic promises; perjury claim rejected.	Plea knowingly and voluntarily entered; extrinsic promise not established.
Whether the appeal waiver bars review of the breach claim	Waiver should not bar review of invalidity/knowingly entered issues.	Waiver may bar breach claim despite remaining questions.	Court addressed validity and found waiver not (alone) blocking review given the related issues.

United States v. O’Doherty, 643 F.3d 209 (7th Cir. 2011) (breach remedies include specific performance or withdrawal as appropriate)
United States v. Schilling, 142 F.3d 388 (7th Cir. 1998) (plea terms reserved government’s right to inform court; lack of implied prohibition)
Whitlow v. United States, 287 F.3d 638 (7th Cir. 2002) (appeal waiver may bar breach review in some circumstances)
United States v. Hare, 269 F.3d 859 (7th Cir. 2001) (discussion of appeal waivers and breach claims)
United States v. Cieslowski, 410 F.3d 353 (7th Cir. 2005) (recognizes review of breach notwithstanding waiver in some contexts)
United States v. Matehopatow, 259 F.3d 847 (7th Cir. 2001) (waiver binding where plea and terms are valid and enforceable)
United States v. Feichtinger, 105 F.3d 1188 (7th Cir. 1997) (establishes framework for plea agreement interpretation)
Bradshaw v. Stumpf, 545 U.S. 175 (2005) (plea validity requires knowing, voluntary, intelligent waiver)
United States v. Peterson, 414 F.3d 825 (7th Cir. 2005) (perjury implications in plea proceedings require compelling explanation)