United States v. Nyandoro: Testing the Miscarriage of Justice Exception

This episode addresses whether a defendant can bypass an appeal waiver following a Supreme Court remand. The defendant, Kenleone Joe Nyandoro, sought to challenge his conviction for firearm possession by an unlawful drug user, arguing the underlying statute was unconstitutional. Under the "miscarriage of justice" exception established in Hunter I, the court evaluated whether the alleged legal errors were obvious and egregious enough to undermine the judiciary's integrity. The court ultimately affirmed the original judgment, concluding that Nyandoro’s constitutional claims were not sufficiently clear to overcome his voluntary agreement to waive his right to appeal. Furthermore, the judges maintained that the district court properly denied his request to withdraw his guilty plea despite evolving legal precedents regarding the Second Amendment.