Buckle up for a Fourth Circuit judge-on-judge benchslap! It stems from a man's guilty plea for robbing a gas station and the appellate waiver in his plea agreement waiving his right to appeal the sentence. Rather than explain what the waiver meant, detail its scope or exceptions, and probe to see if the man understood what he was waiving, the district court "decided 12 years of [his] life in 13 minutes." Fourth Circuit: trial court did not address the man's mitigation arguments or explain how the sentence was reached. In fact, this is the "regular practice of the district court" knowing that it is generally shielded by appeal waivers, and is a "miscarriage of justice that cannot remain unaddressed." Tsk, tsk, tsk. The appeal waiver had not been made knowingly or intelligently, and the sentence itself was procedurally unreasonable. Double yikes!!
By the way, "This district court has also repeatedly and, with increasing frequency, disregarded our precedent regarding procedurally reasonable sentencing hearings." "Unfortunately, we have reversed the court below with increasing frequency to no avail. Heretofore, the district court’s omissions, failures, and disregard for our precedent have been effectively shielded from review by appeal waivers in cases such as the one at hand. No more."
Result: sentence vacated. The man gets new sentencing in front of a new judge.
The case is U.S. v. Quamaine Smith, No. 22-4338 (4th Cir. Apr. 14, 2025).