United States v. Rife, 3:12-cr-00017

Jason Rife pleaded guilty to possession with intent to distribute heroin pursuant to a plea agreement that dismissed nine other counts and included a broad, bolded waiver of his right to appeal or collaterally attack his conviction or sentence (except for ineffective-assistance claims tied to waiver negotiation).
At the change-of-plea hearing Rife affirmed he read and understood the agreement, acknowledged the 20-year statutory maximum, and acknowledged the appeal/collateral-attack waiver; the court accepted his plea.
At sentencing both parties treated Rife as a career offender under U.S.S.G. § 4B1.2 based on four prior Indiana felony convictions; the court imposed 151 months (the agreed low-end Guideline sentence).
Rife did not appeal. After the Supreme Court decided Johnson v. United States (invalidating the ACCA residual clause), Rife filed a § 2255 petition arguing Johnson should apply retroactively to invalidate the similar Guidelines residual clause and eliminate his career-offender status.
The district court declined to reach the merits, holding Rife’s broad, knowing, and voluntary waiver bars his § 2255 challenge and that none of the narrow exceptions to waiver applied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Enforceability of broad plea waiver to bar § 2255 challenge based on Johnson	Rife: Johnson makes the Guidelines residual clause unconstitutional so he should be able to collaterally attack his career-offender enhancement	Government: The plea agreement contains a knowing, voluntary, broad waiver of collateral attack that covers this claim	Waiver is valid and enforceable; bars Rife’s § 2255 petition
Applicability of exceptions to enforce waiver (miscarriage of justice, impermissible basis, statutory max, ineffective assistance)	Rife: Denying review would be a miscarriage of justice—see Tenth Circuit’s Madrid recognizing plain-error after Johnson	Government: Only limited exceptions apply in Seventh Circuit (ineffective assistance related to plea, impermissible sentencing basis, sentence > statutory max); none fit here	No applicable exception: not race/impermissible, sentence below statutory max, no ineffective-assistance claim tied to plea negotiation; Seventh Circuit does not recognize a generalized miscarriage-of-justice exception, so waiver stands

Johnson v. United States, 135 S. Ct. 2551 (2015) (held ACCA residual clause void for vagueness)
Welch v. United States, 136 S. Ct. 1257 (2016) (Johnson announced a substantive rule with retroactive effect on collateral review)
Keller v. United States, 657 F.3d 675 (7th Cir. 2011) (defendant may validly waive direct appeal and collateral review in a plea agreement)
United States v. Sines, 303 F.3d 793 (7th Cir. 2002) (waiver of collateral attack valid if knowing and voluntary; ineffective-assistance exception preserved when tied to plea negotiation)
Bridgeman v. United States, 229 F.3d 589 (7th Cir. 2000) (court presumes truthful sworn statements at plea hearing regarding understanding of plea terms)
Nunez v. United States, 546 F.3d 450 (7th Cir. 2008) (knowing, voluntary waiver ordinarily must be enforced)
United States v. Bownes, 405 F.3d 634 (7th Cir. 2005) (appeal waivers effective despite later favorable changes in law)
United States v. Smith, 759 F.3d 702 (7th Cir. 2014) (Seventh Circuit limits escape from appeal waivers to narrow categories)
Massaro v. United States, 538 U.S. 500 (2003) (ineffective-assistance claims may be raised in § 2255 even if not raised on direct appeal)
United States v. Feichtinger, 105 F.3d 1188 (7th Cir. 1997) (appeal waiver unenforceable if sentence exceeds statutory maximum)