8th Circuit dismissed Timothy Knauff's appeal, ruling he waived his right to appeal when he…
United States v. Timothy Knauff
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8th Circuit dismissed Timothy Knauff's appeal, ruling he waived his right to appeal when he signed a plea agreement, and found no other valid issues to review.
Why it matters
The Eighth Circuit dismissed Timothy Knauff's appeal of his below-Guidelines drug sentence, finding that the appeal waiver he signed as part of his plea agreement was valid and enforceable. His own attorney filed a brief saying there were no strong arguments to make, and after independently reviewing the record, the court agreed there were no non-frivolous issues outside the waiver's scope. The court granted the attorney permission to withdraw and dismissed the appeal.
Who it affects
- Whose appeal was dismissed. More broadly
- Voluntarily
What happens next
Current
Decision issued Jul 13, 2026
Unpublished opinion
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- Decision issued Jul 13, 2026Unpublished opinion
- Possible rehearingParties can ask the same court to reconsider.
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Decision issued
Jul 13, 2026 · Unpublished opinion
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DEEPER READ
Timothy Knauff pleaded guilty to a drug offense in federal court in Minnesota and received a sentence below the recommended Guidelines range. As part of his written plea agreement, he agreed to waive, or give up, his right to appeal his sentence. He appealed anyway, and his attorney, finding no strong legal arguments to support the appeal, filed what is known as an Anders brief. An Anders brief is a formal way for a defense attorney to tell the court that after reviewing the case, they believe the appeal has no merit, while still protecting the defendant's right to have the court take a look. The Eighth Circuit examined whether the appeal waiver in Knauff's plea agreement should be enforced. The court applied a three-part test: Was the waiver within the scope of the appeal being raised? Did the defendant knowingly and voluntarily agree to the plea and the waiver? And would enforcing the waiver result in a miscarriage of justice? The court concluded that all three conditions were satisfied, making the waiver valid and applicable to the issues raised, which included a claimed error in the presentence report and a constitutional challenge to firearm-related sentencing guidelines. Beyond the waiver question, the court independently reviewed the entire record as required when an Anders brief is filed, looking for any non-frivolous issues that might exist outside the scope of the waiver. It found none. As a result, the court granted the attorney's request to withdraw from the case and dismissed the appeal entirely. This decision does not create new law but applies well-established Eighth Circuit rules about when appeal waivers in plea agreements will be honored. There was no dissent noted in the opinion.
CITATION AND RECORD
Record source: CourtListener
United States Court of Appeals For the Eighth Circuit ___________________________ No. 26-1087 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Timothy Michael Knauff lllllllllllllllllllllDefendant - Appellant ____________ Appeal from United States District Court for the District of Minnesota ____________ Submitted: July 6, 2026 Filed: July 13, 2026 [Unpublished] ____________ Before GRUENDER, BENTON, and SHEPHERD, Circuit Judges. ____________ PER CURIAM. Timothy Knauff appeals the below-Guidelines-range sentence the district court1 imposed after he pleaded guilty to a drug offense pursuant to a written plea agreement 1 The Honorable Nancy E. Brasel, United States District Judge for the District of Minnesota. containing an appeal waiver. His counsel has moved to withdraw, and has filed a brief under Anders v. California, 386 U.S. 738 (1967), arguing that an error exists in the presentence report, warranting correction, and that firearm-related Guidelines provisions are unconstitutional. 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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