The Fifth Circuit Court of Appeals has ruled to uphold an appeal waiver in the case of Devin Chaney, who pleaded guilty to Hobbs Act Robbery and Armed Bank Robbery. The court dismissed Chaney's appeal, stating that he did not meet the necessary criteria for a "miscarriage of justice" exception. This ruling came on October 19, 2026, following a remand from the Supreme Court of the United States.
Chaney's case is significant because it addresses the enforceability of plea agreements and the circumstances under which a defendant can appeal their sentence. The court's decision impacts those who have entered similar agreements, as it reinforces the idea that waivers can limit a defendant's ability to challenge their sentence.
Background
Devin Chaney was charged with multiple counts, including Hobbs Act Robbery under 18 U.S.C. § 1951(a) and Armed Bank Robbery under 18 U.S.C. § 2113(a) and (d). In a plea agreement, Chaney waived his right to appeal, except in cases where his sentence exceeded the statutory maximum or he could claim ineffective assistance of counsel. In exchange for his guilty plea, the government dropped nine other counts against him.
Despite this waiver, Chaney appealed his sentence, arguing that the district court improperly classified him as a career offender under the U.S. Sentencing Guidelines. Initially, the Fifth Circuit dismissed his appeal, stating that his waiver was "knowing and voluntary" and applicable to the circumstances. However, after the Supreme Court's decision in Hunter v. United States, which established a "miscarriage of justice" exception to appeal waivers, Chaney's case was remanded for reconsideration.
The Ruling
Upon remand, the Fifth Circuit ruled that Chaney's appeal waiver would still be enforced. The court stated that Chaney did not identify any egregious error in his sentencing process that would justify overturning the waiver. The opinion, written by Circuit Judge Jerry E. Smith, noted, "Because Chaney has identified no such egregious error in his own sentence or sentencing process, we once again enforce his appeal waiver and dismiss the appeal."
The court referenced the Supreme Court's description of the "miscarriage of justice" exception as a "high bar" meant for extreme cases. The court explained that errors must be obvious and not ones a judge could reasonably make. The Fifth Circuit emphasized that Chaney's claims did not meet this high standard, stating, "Standard-fare errors in misapplying sentencing law cannot cancel an appeal waiver."
Impact
This ruling has significant implications for defendants who enter plea agreements with appeal waivers. It clarifies that the courts will uphold these waivers unless a defendant can demonstrate a clear and egregious error that meets the stringent criteria outlined by the Supreme Court. This decision reinforces the importance of thorough legal counsel during plea negotiations, as defendants may be limited in their ability to challenge sentences later.
The ruling also sets a precedent for future cases involving similar appeal waivers, indicating that the courts will likely enforce these agreements unless the circumstances are extraordinary. This could deter defendants from appealing sentences in cases where they have waived their rights, thus streamlining the judicial process.
What's Next
Chaney's case may not be the last word on appeal waivers, as it remains possible for him to seek further review from the Supreme Court. However, given the court's recent ruling and the high bar for establishing a miscarriage of justice, it is uncertain whether any further legal action will succeed.