United States v. Mark-Anthony Adams
414 U.S. App. D.C. 302
D.C. Cir.2015Background
- Mark-Anthony Elisha Adams pleaded guilty to one count of conspiracy to commit wire and mail fraud related to a scheme against USAID; 21 other counts were dismissed per plea agreement.
- The plea agreement acknowledged the Sentencing Guidelines range (51–63 months) and stated that a Guidelines sentence would be reasonable.
- Adams expressly waived his right to appeal his sentence or the manner it was determined under 18 U.S.C. § 3742, except for two narrow exceptions: (a) sentence above statutory maximum, or (b) upward departure under U.S.S.G. § 5K.2 or based on 18 U.S.C. § 3553(a) factors.
- At sentencing the district court imposed the bottom of the Guidelines range: 51 months imprisonment, three years supervised release, and restitution.
- Adams sought to appeal, raising three challenges to sentencing procedure and substance: denial of motion to delay sentencing for further medical evidence, limitation on cross-examination of the Government’s witness about prison medical care, and that his sentence was substantively unreasonable.
- The government moved to enforce the appeal waiver; the D.C. Circuit evaluated whether enforcement would produce a miscarriage of justice or whether ineffective assistance invalidated the waiver.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Enforceability of appeal waiver | Adams argued his procedural complaints should survive the waiver because the court misapplied discretion and limited his ability to present medical mitigation | Government argued the waiver was knowing and voluntary and bars these challenges | Waiver enforceable; appellate review dismissed because Adams did not show miscarriage of justice or ineffective assistance |
| Miscarriage of justice exception | Adams claimed district court’s refusal to delay sentencing and curtailment of cross-examination produced a miscarriage of justice | Gov’t: Those are discretionary errors, not the type of fundamental procedural defects that negate a waiver | Court held errors alleged were ordinary discretionary rulings and not within narrow miscarriage exception |
| Ineffective assistance claim | Adams did not raise ineffective assistance here | Gov’t asserted no colorable ineffective-assistance claim presented | Court noted waiver may be invalid for colorable ineffective-assistance claim, but Adams made none |
| Claim of substantive unreasonableness | Adams argued the sentence was substantively unreasonable given his health and other mitigation | Gov’t relied on the plea agreement waiver covering substantive and procedural challenges | Court held substantive and procedural challenges barred by valid waiver |
Key Cases Cited
- United States v. Guillen, 561 F.3d 527 (D.C. Cir.) (explaining enforceability of appellate waivers and narrow miscarriage-of-justice exception)
- United States v. Andis, 333 F.3d 886 (8th Cir.) (appeal waivers bar challenges to guideline application and discretionary sentencing)
- United States v. Buissereth, 638 F.3d 114 (2d Cir.) (appeal waiver limits appellate correction of alleged procedural errors)
- United States v. Soto-Cruz, 449 F.3d 258 (1st Cir.) (enforcement of waiver despite claim district denied mitigation evidence)
- United States v. Blue Coat, 340 F.3d 539 (8th Cir.) (describing miscarriage-of-justice exception to waiver as very narrow)