Puckett v. United States

Defendant agreed to cooperate with the government and pleaded guilty to armed bank robbery and use of a firearm during a crime of violence. In exchange, the government agreed to apply a three-level reduction and place defendant’s sentence at the lowest end of the applicable level under the federal Sentencing Guidelines. While awaiting sentencing, defendant aided a fellow inmate in a scheme to defraud the Postal Service. The government consequently reneged. Defendant never objected that the government was violating its obligations under the plea agreement. Despite forfeiting the claim, he raised the issue on appeal. The Court held that the plain-error standard of review from Fed. R. Crim. P. 52(b) applies to forfeited claims and reiterated its four prongs of analysis. A defendant must show that (1) a clear and obvious legal error exists; (2) such error has not been affirmatively waived; (3) such error affected his substantial rights; and (4) such error seriously affected the fairness, integrity, or public reputation of judicial proceedings. The Court not only emphasized that defendant failed to preserve the issue by objection, but also rejected defendant’s arguments that the government’s breach of the agreement retroactively made his guilty plea unknowing and involuntary.

“Application of plain-error review in the present context is consistent with our cases[.] . . . While we recognize that the Government’s breach of a plea agreement is a serious matter, “the seriousness of the error claimed does not remove consideration of it from the ambit of the Federal Rules of Criminal Procedure.” p.143