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Circuits Split on Booker's Effect on Plea Agreements
The United States Circuit Courts of Appeals have reached different results in applying United States v. Booker to pre-Booker plea agreements. In United States v. Bond, 2005 WL 1459641 (5th Cir. June 21, 2005), the Fifth Circuit held that the defendant's appeal of his sentence based on Booker error was barred by his plea agreement, which included an appeal-waiver provision.
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