US v. Carlos Grooms
Split Score
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Case Summary
Disposition
Affirmed
The Fourth Circuit affirmed Carlos Antonio Grooms’s 360-month sentence and rejected his challenge to a supervised-release drug-testing condition. The court held that, under its recent decision in United States v. Jones, the condition did not constitute an unconstitutional delegation and therefore declined to excise it notwithstanding Grooms’s request that the court adopt the Ninth Circuit’s appeal-waiver exception for anti-delegation claims.
Circuit Split Identified
Legal Issue
Whether anti-delegation challenges to supervised-release conditions are exempt from otherwise valid appellate-waiver provisions in plea agreements.
Circuit Positions
Anti-delegation challenges fall outside the scope of an appeal waiver and may be raised on appeal.
Anti-delegation challenges are not excepted from an appeal waiver; the court will enforce the waiver or decide the claim on the merits without creating an exception.
Conflict Summary
The Ninth Circuit treats anti-delegation challenges to supervised-release conditions as outside the scope of standard appeal waivers, allowing defendants to raise such claims despite the waiver. By contrast, the Fourth Circuit has not recognized any such exception and, in this case, resolved the appeal on the merits without adopting the Ninth Circuit’s approach, effectively enforcing (or at least not negating) the waiver.