A federal appeals court has dismissed the appeal of Darryl Payne, who was sentenced to 12 months and one day in prison for failing to register under the Sex Offender Registration and Notification Act (SORNA). The Eleventh Circuit Court of Appeals ruled that Payne had waived his right to appeal as part of a plea agreement. This ruling underscores the importance of understanding the implications of plea agreements in criminal cases.

The case, United States v. Darryl Payne, was filed under docket number 26-10590 and was decided on November 3, 2026. The court's decision affects Payne, who had hoped to challenge the length of his sentence, claiming it was substantively unreasonable. However, the court found that he had knowingly and voluntarily waived his right to appeal.

Background

Darryl Payne faced charges for failing to register as a sex offender, a requirement stemming from his prior conviction. In March 2025, a grand jury indicted him on one count of failing to register under SORNA, violating 18 U.S.C. § 2250(a). After negotiating a plea agreement, Payne pled guilty to the charge. In exchange, the government agreed not to pursue additional charges against him and recommended a lower sentence.

The plea agreement included a waiver of most of Payne's appellate rights, stating that he was giving up the right to appeal his conviction or sentence except in specific circumstances, such as claims of ineffective assistance of counsel. During the change-of-plea hearing, a magistrate judge ensured that Payne understood the agreement and the implications of waiving his appeal rights.

The Ruling

The Eleventh Circuit Court, comprising Circuit Judges Branch, Luck, and Abudu, ruled to dismiss Payne's appeal. The court stated, "Payne knowingly and voluntarily waived his right to appeal his sentence, his challenge on appeal falls within the scope of that waiver, and no exception applies." The judges noted that Payne's argument that his sentence was unreasonable did not meet the criteria for any exceptions to the waiver.

The court emphasized that sentence appeal waivers are enforceable if made knowingly and voluntarily. In this case, Payne had signed the plea agreement, confirming that he understood its terms, including the waiver of his right to appeal. The court highlighted that the magistrate judge had specifically questioned Payne about the appeal waiver during the plea colloquy, ensuring he comprehended its significance.

Impact

This ruling reinforces the legal principle that defendants must fully understand the consequences of plea agreements, especially regarding appeal rights. It serves as a reminder that waivers can limit a defendant's ability to challenge their sentence, even if they believe it to be unreasonable. The decision may also influence future cases involving plea agreements and sentence appeal waivers, emphasizing the need for clear communication between defendants and their legal counsel.

Payne's case illustrates the complexities of navigating the legal system, particularly for individuals with prior convictions. The court's ruling may deter other defendants from attempting to appeal sentences if they have signed similar waivers in their plea agreements.

What's Next

Given that the Eleventh Circuit dismissed the appeal, there are limited options for Payne moving forward. He cannot appeal this decision further due to the waiver in his plea agreement. There are no indications in the court filing about any related cases pending that may affect this ruling.