This Court has recognized that "no appeal waiver serves as an absolute bar to all appellate claims." Garza v. Idaho, 586 U.S. 232, 238 (2019). But the Court has "ma[de] no statement … on what particular exceptions [to appeal waivers] may be required." Id. at 238-39 & n.6.

In the absence of this Court's guidance, the circuits have been intractably split over what exceptions to recognize for general appeal waivers. The Eleventh Circuit falls on the side with only narrow exceptions to appeal waivers and refuses to acknowledge an exception for miscarriages of justice.

Is one of the permissible exceptions to a general appeal waiver a miscarriage-of-justice exception?

Whether a miscarriage-of-justice exception is a permissible exception to a general appeal waiver in criminal cases