8th Circuit dismissed Tazell Williams's appeal, finding he had validly waived his right to appeal…
United States v. Tazell Williams
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8th Circuit dismissed Tazell Williams's appeal, finding he had validly waived his right to appeal his sentence when he signed his plea agreement.
Why it matters
The Eighth Circuit dismissed Tazell Williams's appeal of his sentence after he pleaded guilty to drug conspiracy and firearm offenses. The court found that the appeal waiver Williams signed as part of his written plea agreement was valid, enforceable, and covered the issues he tried to raise. After independently reviewing the record, the court also found no non-frivolous issues outside the scope of the waiver, so it allowed his lawyer to withdraw and dismissed the appeal.
Who it affects
- Whose appeal was dismissed. More broadly
- Voluntarily
What happens next
Current
Decision issued Jul 16, 2026
Unpublished opinion
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- Decision issued Jul 16, 2026Unpublished opinion
- Possible rehearingParties can ask the same court to reconsider.
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Decision issued
Jul 16, 2026 · Unpublished opinion
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DEEPER READ
Tazell Williams pleaded guilty in federal district court in the Eastern District of Missouri to drug conspiracy and firearm offenses. As part of his written plea agreement, he agreed to waive his right to appeal his sentence. After being sentenced, he attempted to appeal anyway, and his attorney filed a special brief under Anders v. California, which is a procedure lawyers use when they believe an appeal has no merit but want to protect a client's rights, while also asking the court for permission to withdraw from the case. The central question before the Eighth Circuit was whether Williams's appeal waiver should be enforced, which would end the appeal without the court examining the merits of his sentencing claims. The court reviewed the waiver from scratch (a legal standard called 'de novo' review) and concluded it was valid and applicable to the issues Williams raised. To enforce an appeal waiver, the court applied a three-part test drawn from its prior decisions: the appeal must fall within the scope of the waiver, the defendant must have entered into the plea agreement and waiver knowingly and voluntarily, and enforcing the waiver must not result in a miscarriage of justice. All three conditions were met here, so the court enforced the waiver. The court also independently reviewed the full record under a standard from Penson v. Ohio, a process courts use to protect defendants even when their own attorneys find no viable arguments. That review turned up no non-frivolous issues outside the waiver's scope. As a result, the court granted the attorney permission to withdraw and dismissed the appeal entirely. The opinion was issued as unpublished and was unanimous among the three judges, with no dissent noted.
CITATION AND RECORD
Record source: CourtListener
United States Court of Appeals For the Eighth Circuit ___________________________ No. 26-1029 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Tazell Teandre Williams lllllllllllllllllllllDefendant - Appellant ____________ Appeal from United States District Court for the Eastern District of Missouri - St. Louis ____________ Submitted: July 9, 2026 Filed: July 16, 2026 [Unpublished] ____________ Before GRUENDER, SHEPHERD, and JUSTIN D. SMITH, Circuit Judges. ____________ PER CURIAM. Tazell Williams appeals the sentence the district court1 imposed after he pleaded guilty to drug conspiracy and firearm offenses pursuant to a written plea 1 The Honorable John A. Ross, United States District Judge for the Eastern District of Missouri. agreement containing an appeal waiver. His counsel has filed a brief under Anders v. California, 386 U.S. 738 (1967), seeking leave to withdraw and challenging Williams’s sentence. We conclude that the appeal waiver is valid, enforceable, and applicable to the issues raised in this appeal. See United States v. Scott, 627 F.3d 702, 704 (8th Cir. 2010) (reviewing de novo the validity and applicability of an appeal waiver); United States v. Andis, 333 F.3d 886, 889-92 (8th Cir. 2003) (en banc) (stating that an appeal waiver will be enforced if the appeal falls within the scope of the waiver, the defendant knowingly and voluntarily entered into the plea agreement and the waiver, and enforcing the waiver would not result in a miscarriage of justice). Having independently reviewed the record pursuant to Penson v. Ohio, 488 U.S. 75 (1988), we find no non-frivolous issues for appeal outside the scope of the appeal waiver. Accordingly, we grant counsel leave to withdraw and dismiss this appeal. ______________________________ -2-
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