The Fifth Circuit Court of Appeals has dismissed the appeal of Rashon Jermaine Harris, who was sentenced to 240 months in prison for possession of methamphetamine with intent to distribute. This decision, issued on October 29, 2026, follows a remand from the U.S. Supreme Court, which clarified the standards for enforcing appeal waivers in criminal cases. The ruling has significant implications for defendants who plead guilty and waive their right to appeal.
Harris's case began when he pled guilty under 21 U.S.C. § 841(a) and (b)(1)(C) to the charges against him. His sentence was enhanced based on his conduct during a police chase, which he argued was unjustified. The Fifth Circuit's dismissal of his appeal means that his lengthy prison sentence will stand, despite his claims of error in the sentencing process.
The appeal arose after Harris initially pled guilty and was sentenced in the Southern District of Mississippi. Following his guilty plea, he attempted to appeal the sentence, arguing that the district court improperly applied sentencing enhancements under the U.S. Sentencing Guidelines. However, the government contended that Harris had waived his right to appeal as part of his plea agreement, which led to the initial dismissal of his appeal.
After the Supreme Court's ruling in Hunter v. United States, which established that appeal waivers could be set aside in cases of a miscarriage of justice, Harris's case was sent back to the Fifth Circuit for reconsideration. The Supreme Court's decision emphasized that waivers are unenforceable if they would result in a significant error that undermines the integrity of the judicial system.
Upon reviewing Harris's case, the Fifth Circuit concluded that there was no miscarriage of justice that would allow Harris to bypass his appeal waiver. The court stated, "We therefore enforce Harris’s appeal waiver against him and DISMISS this case." This ruling indicates that the court found no egregious error in the application of the sentencing enhancements that would justify overriding the waiver.
The Fifth Circuit's opinion highlighted the high bar set by the Supreme Court for establishing a miscarriage of justice. The court noted that a waiver may be set aside only if the sentence includes an error that is obvious and not one a reasonable judge could make. They pointed out that typical errors in sentencing law, such as miscalculations in the Sentencing Guidelines, do not qualify as miscarriages of justice.
In his appeal, Harris raised two main arguments against the enforcement of his waiver. First, he claimed that his guilty plea was not made knowingly and voluntarily because it occurred on the same day as his initial appearance. However, the court found that Harris had sufficient understanding of his plea agreement and the consequences of waiving his appeal rights. The record showed that he had read and discussed the agreement with his attorney, and he confirmed his understanding in court.
Second, Harris argued that the district court's reliance on U.S.S.G. § 3C1.2, which enhances sentences for defendants who create a substantial risk of death or serious injury while fleeing law enforcement, constituted a miscarriage of justice. He contended that since no one was harmed during his flight, the enhancement was unjustified. However, the court ruled that the enhancement did not require actual harm to have occurred, and the district court had a factual basis for its decision based on witness testimony regarding Harris's reckless driving.
The Fifth Circuit's ruling reinforces the importance of plea agreements and the enforceability of appeal waivers in the criminal justice system. It clarifies that defendants who enter into plea agreements must fully understand the implications of waiving their right to appeal, and that typical sentencing errors do not provide grounds for overturning such waivers.
Moving forward, this decision may affect how future defendants approach plea agreements and their understanding of appeal rights. The ruling emphasizes the need for defendants to be fully informed about the consequences of their decisions when entering guilty pleas. Additionally, it sets a precedent for how courts will handle similar cases involving appeal waivers in the wake of the Supreme Court's Hunter decision.
As for Harris, the dismissal of his appeal means he will serve his sentence without the possibility of contesting the enhancements imposed during his sentencing. Details about whether Harris will seek further legal recourse or if there are related cases pending were not available in the court filing.
Read Next
Fifth Circuit upholds conviction of Gregory Cook for firearm possession
Fifth Circuit to Rehear Case Involving Texas Attorney General
Fifth Circuit rules on supervised release conditions in drug case
California Court of Appeal affirms ruling in Kirby case
New York court affirms manslaughter conviction of Rodriguez
New York court affirms judgment in People v. Toms appeal










