United States v. Sanchez-LaPorte: Reaffirming the Enforceability of Appeal Waivers in Anders Appeals

Introduction

United States v. Pedro Sanchez-LaPorte (3d Cir. July 2, 2025) is an unpublished opinion that nonetheless adds a cogent, up-to-date articulation of how the U.S. Court of Appeals for the Third Circuit treats (1) Anders withdrawal motions and (2) plea-agreement appellate waivers when those two procedural devices intersect. The case arose from Sanchez-LaPorte’s participation in a violent narcotics trafficking enterprise and culminated in a guilty plea to conspiracy, firearm, and 18 U.S.C. § 924(j) murder charges. Despite receiving a below-Guidelines sentence of 198 months, the defendant filed a notice of appeal; his counsel simultaneously moved to withdraw under Anders v. California, 368 U.S. 738 (1967).

The Third Circuit, in a panel consisting of Judges Shwartz, Freeman, and Smith, granted counsel’s motion and enforced the appellate waiver, reiterating the now-familiar three-part Langley test (scope, knowledge/voluntariness, and miscarriage-of-justice) and linking it to the two-step Youla/Brookins inquiry that governs Anders briefs. Although marked “Not Precedential,” the opinion synthesizes newer Circuit authority—most notably United States v. Brookins, 132 F.4th 659 (3d Cir. 2025)—and therefore offers useful practical guidance for defense counsel and district courts alike.

Summary of the Judgment

The panel conducted a combined Anders and appellate-waiver analysis.
It found counsel’s brief satisfied Third Circuit L.A.R. 109.2(a) because counsel:
1. performed a thorough review of the record, and
2. explained why any conceivable issue was frivolous.
The court enforced the waiver after determining:
1. Scope: none of the four carve-outs (government appeal, sentence above statutory max, upward departure/variance, or ineffective assistance) applied;
2. Knowledge & Voluntariness: the plea colloquy and signed documents showed an informed and voluntary waiver; and
3. No Miscarriage of Justice: no clear, grave error was present.
Counsel’s motion to withdraw was granted and the conviction and sentence were affirmed.

In-Depth Analysis

1. Precedents Cited and Their Influence

Anders v. California, 368 U.S. 738 (1967) – Established the withdrawal-of-counsel procedure when an appeal is “wholly frivolous.”
United States v. Youla, 241 F.3d 296 (3d Cir. 2001) – Created a two-pronged test for evaluating Anders briefs (adequate review by counsel and independent review by the court).
United States v. Brookins, 132 F.4th 659 (3d Cir. 2025) – The newest published elaboration on the “arguable merit” standard and the court’s plenary review in Anders settings.
• Sanchez-LaPorte embeds Brookins into regular Anders jurisprudence, signaling its now-settled authority.
United States v. Langley, 52 F.4th 564 (3d Cir. 2022) – Supplies the three-part rule for enforcing appellate waivers that the panel follows step-by-step.
United States v. Grimes, 739 F.3d 125 (3d Cir. 2014) – Clarified that appellate waivers do not remove jurisdiction but do limit the court’s willingness to reach the merits.
Menna v. New York, 423 U.S. 61 (1975) and United States v. Broce, 488 U.S. 563 (1989) – Confirm that guilty pleas generally waive most defenses except jurisdictional challenges and certain constitutional defects.

Together, these authorities create a coherent doctrinal ladder: Anders → Youla/Brookins (procedural adequacy); Langley/Grimes (substantive waiver-enforcement). The panel walks that ladder meticulously, and by citing Brookins—a case decided only months earlier— signals that Brookins is now a controlling gloss on Anders practice in the Circuit.

2. Court’s Legal Reasoning

Step One – Anders Adequacy.
The panel inspected counsel’s Anders brief for: (a) thorough record review and (b) explanation of frivolity. Finding both, the court moved to its independent review.
Step Two – Independent Review & Waiver Analysis.
The panel reaffirmed that when an appellate waiver exists, the independent review naturally starts with determining its validity. Applying the Langley trilogy:
- Scope – The plea’s carve-outs were inapplicable.
- Knowledge/Voluntariness – The colloquy ticked every Rule 11 box.
- Miscarriage of Justice – No clear error; sentence below Guidelines and statutory maximum.
Step Three – Disposition.
Because the waiver barred any arguable claim, the panel affirmed the judgment and granted the Anders withdrawal motion.

3. Potential Impact of the Judgment

Although “not precedential,” the opinion carries several practical consequences:

Operational Blueprint. District courts and counsel gain a checklist-style opinion tying Brookins to waiver enforcement. Future Anders submissions will likely mirror the structure employed here.
Sentencing Mergers Clarified. The panel notes in a footnote that § 924(c) (discharge of a firearm) merged into § 924(j) (murder) for sentencing. While not fully developed, the remark flags how overlapping firearm counts may be handled in the Third Circuit after United States v. Givens and other merger precedent.
Miscarriage-of-Justice Threshold. The opinion reinforces that the Third Circuit’s threshold is very high. A below-Guidelines sentence almost never meets that standard unless new legal error emerges.
Defense Strategy. Practitioners are reminded to: (a) craft waiver language precisely, and (b) advise clients carefully about the severe limitation on appellate rights, because enforcement remains the norm.

Complex Concepts Simplified

Anders Brief: A document filed by counsel stating that, after a diligent search, the appeal is meritless. Counsel seeks to withdraw, yet must still point to anything arguably supportive of the client.
Plea-Agreement Appellate Waiver: A contractual provision in which a defendant, in return for concessions (often a reduced sentence), waives part or all of the right to appeal or file collateral attacks, with specified exceptions.
Miscarriage of Justice Exception: An equitable safety valve. Even with a valid waiver, the court may refuse enforcement if doing so would be fundamentally unfair—e.g., an illegal sentence, racial bias, or newly discovered actual innocence.
Guidelines Range vs. Statutory Maximum: The Guidelines range is advisory and based on offense level + criminal history. The statutory maximum is the absolute ceiling set by Congress for that offense. A sentence that stays below the statutory maximum but also beneath the Guidelines is usually unassailable.
18 U.S.C. § 924(j): Criminalizes murder “in the course of” a violation of § 924(c), allowing life imprisonment or death. Counts under § 924(c) may merge into § 924(j) at sentencing because § 924(j) contains § 924(c) as a predicate.

Conclusion

United States v. Sanchez-LaPorte does not blaze a new doctrinal trail, but it consolidates recent authority—especially Brookins—into a concise road map: when a defendant executed an informed appellate waiver, and counsel’s Anders brief is facially adequate, the Third Circuit will enforce the waiver and summarily affirm absent “manifest injustice.” The opinion thus fortifies the Circuit’s strong stance on the finality of negotiated guilty pleas while offering litigants a clear procedural template for Anders/waiver cases going forward.