8th Circuit dismissed Darnell Clemons's appeal, enforcing the appeal waiver he signed as part of…
United States v. Darnell Clemons
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8th Circuit dismissed Darnell Clemons's appeal, enforcing the appeal waiver he signed as part of his guilty plea to carjacking and firearms offenses.
Why it matters
The Eighth Circuit dismissed Darnell Clemons's appeal after finding that the appeal waiver in his plea agreement was valid and enforceable. The court found that Clemons had confirmed under oath at his plea hearing that he understood the agreement, was satisfied with his lawyer, and was not pressured to plead guilty. His claims of ineffective assistance of counsel, sentencing errors, and prosecutorial misconduct were either covered by the waiver, better suited for a different type of legal proceeding, or given up when he pleaded guilty.
Who it affects
This ruling directly affects Darnell Clemons, whose appeal was dismissed. More broadly, it reinforces that defendants who sign appeal waivers as part of plea agreements will generally be held to those waivers, which is relevant to anyone who pleads guilty to a federal crime under similar terms.
What happens next
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Decision issued Jul 21, 2026
Unpublished opinion
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- Decision issued Jul 21, 2026Unpublished opinion
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Jul 21, 2026 · Unpublished opinion
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DEEPER READ
Darnell Clemons pleaded guilty in federal court in the Eastern District of Missouri to carjacking, ammunition, and firearms offenses. As part of his plea agreement, he signed an appeal waiver, which is a provision in which a defendant gives up most rights to appeal the conviction and sentence. After he was sentenced, his court-appointed lawyer reviewed the record, concluded there were no valid issues to appeal, and asked the court for permission to withdraw. Clemons also filed his own brief raising claims of ineffective assistance of counsel and prosecutorial misconduct. The Eighth Circuit reviewed whether the appeal waiver should be enforced. The court looked at three main questions: whether Clemons entered into the waiver knowingly and voluntarily, whether his claims fell within the scope of the waiver, and whether enforcing the waiver would result in a miscarriage of justice. On the first question, the court pointed to Clemons's own sworn statements at the plea hearing, where he said he understood the agreement, was satisfied with his attorney, had no questions, and had not been threatened or coerced. Those statements contradicted his later claim that he did not knowingly agree to the waiver. On the second question, the court found that Clemons's challenges to his sentencing calculations and his prosecutorial misconduct claims both fell within the scope of the waiver. The court also noted that claims of prosecutorial misconduct are generally given up when a defendant pleads guilty. As for the ineffective assistance of counsel claims, the court did not dismiss them as frivolous but said they are more appropriately handled through a separate collateral review process, not a direct appeal. On the third question, the court found no miscarriage of justice that would require overriding the waiver. After independently reviewing the entire record, the court also found no valid issues for appeal outside the waiver's scope. There was no dissent. The court dismissed the appeal, enforced the appeal waiver, and allowed Clemons's attorney to withdraw.
CITATION AND RECORD
Record source: CourtListener
United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-2333 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Darnell L. Clemons lllllllllllllllllllllDefendant - Appellant ____________ Appeal from United States District Court for the Eastern District of Missouri - St. Louis ____________ Submitted: July 16, 2026 Filed: July 21, 2026 [Unpublished] ____________ Before LOKEN, L.R. SMITH, and BENTON, Circuit Judges. ____________ PER CURIAM. Darnell Clemons appeals after he pleaded guilty to carjacking, ammunition, and firearms offenses, pursuant to a plea agreement containing an appeal waiver. His counsel has moved to withdraw and has filed a brief under Anders v. California, 386 U.S. 738 (1967), concluding that there are no non-frivolous issues for appeal after thoroughly reviewing the record. In a pro se supplemental brief, Clemons raises claims of ineffective assistance of trial counsel and prosecutorial misconduct. After de novo review, we will enforce the appeal waiver. See United States v. Scott, 627 F.3d 702, 704 (8th Cir. 2010) (standard of review); United States v. Andis, 333 F.3d 886, 889-92 (8th Cir. 2003) (en banc). First, Clemons’s statements to the district court1 at the change-of-plea hearing contradict any suggestion that he unknowingly or involuntarily entered into the plea agreement or appeal waiver, as he testified under oath that he understood the maximum potential penalties and the terms of the plea agreement and appeal waiver; he was fully satisfied with counsel; he had no questions; no one had promised or predicted what sentence he might receive; and no one had forced, threatened, or coerced him to plead guilty. See Andis, 333 F.3d at 890-91; Nguyen v. United States, 114 F.3d 699, 703 (8th Cir. 1997). To the extent he claims that trial counsel provided ineffective assistance in connection with the plea and other aspects of his proceedings, we conclude those claims are more appropriate for collateral review. See United States v. Ramirez-Hernandez, 449 F.3d 824, 826-27 (8th Cir. 2006); see also United States v. Griffin, 668 F.3d 987, 989-91 (8th Cir. 2012). Second, Clemons’s implicit pro se challenges to the sentencing calculations fall within the scope of the appeal waiver, and his claims of prosecutorial misconduct both fall within the scope of the waiver and were otherwise waived by pleading guilty. See Scott, 627 F.3d at 704; United States v. Cain, 134 F.3d 1345, 1352-53 (8th Cir. 1998). Third, no miscarriage of justice would result from enforcing the appeal waiver. See Hunter v. United States, 146 S. Ct. 1702, 1708, 1713-14 (2026); Andis, 333 F.3d at 891-92. Finally, having independently reviewed the record under Penson v. Ohio, 488 U.S. 75 (1988), we have found no non-frivolous issues for appeal outside the scope of the appeal waiver. 1 The Honorable Henry E. Autrey, United States District Judge for the Eastern District of Missouri. -2- Accordingly, we dismiss the appeal based on the appeal waiver, and we grant counsel’s motion to withdraw. ______________________________ -3-
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