United States v. Grindle: Mental-Health Challenges Do Not Automatically Vitiate Knowing & Voluntary Sentence-Appeal Waivers

Introduction

United States v. Nicholas Grindle (11th Cir. Aug. 15, 2025) presented the Eleventh Circuit with a familiar but frequently contested question: When, if ever, will a defendant’s documented mental-health challenges invalidate a sentence-appeal waiver contained in a plea agreement? Mr. Grindle, a former Georgia corrections officer, pleaded guilty to conspiracies involving drug distribution and prison bribery. He received an 87-month sentence—at the low end of the advisory Guidelines—and nevertheless sought appellate review on procedural and substantive reasonableness grounds. The Government moved to dismiss, invoking the broad appeal waiver in the plea agreement. The panel (Lagoa, Kidd & Marcus, JJ.) enforced the waiver and dismissed the appeal, clarifying the circumstances under which mental-health evidence may (or, as here, may not) undermine the “knowing and voluntary” character of an appeal waiver.

Summary of the Judgment

Issue: Whether Mr. Grindle’s sentence-appeal waiver was enforceable despite his bipolar disorder and lapsed medication regimen.
Holding: The waiver was knowingly and voluntarily executed; none of the stated exceptions applied; the appeal is dismissed.
Key Facts Relied Upon:
- Comprehensive Rule 11 colloquy specifically addressing the waiver and its exceptions.
- Defendant’s unequivocal, sworn confirmation that he understood the waiver and was competent.
- Counsel’s statement that he had no competency concerns.
- Sentence was within (indeed, at the bottom of) the calculated Guidelines range; Government filed no cross-appeal.
Result: Government’s motion to dismiss granted; appeal dismissed.

Analysis

A. Precedents Cited and Their Influence

United States v. Bushert, 997 F.2d 1343 (11th Cir. 1993) – Established that appeal waivers are enforceable if “knowing & voluntary.” The Grindle panel relies on Bushert as the foundational test.
United States v. Buchanan, 131 F.3d 1005 (11th Cir. 1997) – Authorizes dismissal at the motion stage when the record clearly shows a valid waiver. The panel invokes Buchanan to justify summary dismissal without merits briefing.
United States v. Dixon, 901 F.3d 1322 (11th Cir. 2018) – Held that cognitive deficits do not nullify a waiver when the defendant affirmatively demonstrates understanding. The current decision extends Dixon by applying the principle to bipolar disorder and unmedicated status.
Winthrop-Redin v. United States, 767 F.3d 1210 (11th Cir. 2014) – Statements made under oath in a plea colloquy carry a “strong presumption of truth.” The panel uses this presumption to discount later competency claims.
Additional cites (Johnson, Benitez-Zapata, Rubbo, Boyd) supply standard of review and interpretive guidance for plea agreements.

B. The Court’s Legal Reasoning

Contractual Approach. Plea agreements are construed like contracts; the waiver clause was unambiguous.
Rule 11 Compliance. The district court specifically questioned Grindle about the waiver, satisfying Fed. R. Crim. P. 11(b)(1)(N).
Mental-Health Inquiry. The court directly addressed bipolar disorder and medication history, determined Grindle was not in a manic or depressive state, and credited both counsel’s and Grindle’s assurances of competency.
Presumption of Truthfulness. Sworn answers during the colloquy are controlling absent “extraordinary circumstances.”
No Triggering Exception. The three carve-outs (Government appeal, upward departure/variance, ineffective assistance) were not implicated.

C. Potential Impact

Plea-Bargaining Landscape: Prosecutors may take confidence in the robustness of appeal waivers even where the defendant has documented mental-health conditions, provided a thorough colloquy is conducted.
Defense Counsel Obligations: Counsel must create a record—beyond mere diagnosis—that the client is incompetent or unable to comprehend the waiver; otherwise, later challenges will be foreclosed.
District Court Practice: Judges are reminded to probe not merely for the existence of a mental condition but its current functional impact on decision-making. The decision evidences appellate deference when this is done.
Substantive Sentencing Review: Defendants may find themselves entirely barred from challenging within-Guidelines sentences if the waiver is broad; “reasonableness” issues will not reach the court of appeals.

Complex Concepts Simplified

Sentence-Appeal Waiver: A clause in a plea agreement where the defendant relinquishes the right to challenge the sentence on appeal, subject to narrow exceptions.
Plea Colloquy: A judge-conducted, on-the-record dialogue ensuring the defendant understands the rights relinquished by pleading guilty.
Knowing & Voluntary Standard: The defendant must comprehend (1) the nature and consequence of the waiver and (2) act without coercion.
Procedural vs. Substantive Reasonableness:
- Procedural – Did the district court follow correct sentencing steps (calculate Guidelines, consider factors)?
- Substantive – Is the length of the sentence reasonable in light of 18 U.S.C. § 3553(a)?
Both lines of attack are foreclosed by a valid waiver.
Guideline Range: The advisory imprisonment range produced by the U.S. Sentencing Guidelines; here, 87–108 months.
Upward Departure/Variance: When a court selects a sentence above the Guideline range (departure) or outside the range based on § 3553(a) factors (variance). Grindle could have appealed only if this occurred.

Conclusion

United States v. Grindle reinforces a critical rule in federal criminal practice: A defendant’s diagnosed mental illness—standing alone—does not undermine a sentence-appeal waiver that is expressly discussed and accepted during a careful Rule 11 colloquy. The decision extends Dixon in emphasizing functional competency over clinical labels and solidifies the Eleventh Circuit’s willingness to summarily dismiss appeals that run afoul of a valid waiver. Going forward, counsel and courts alike must recognize that the linchpin remains the record created at the plea hearing; absent clear evidence of incapacity or coercion, appellate doors will remain firmly closed.