No. 25-7238

Eddy Reyes v. United States

Lower Court: Ninth Circuit
Docketed: 2026-04-22
Status: Pending
Type: IFP
IFP
Tags: criminal-procedure plain-error-review plea-agreement rule-11-c-1-c santobello-doctrine sentencing
Latest Conference: N/A
Question Presented (from Petition)

I. Whether an explicit breach of a Rule 11(c)(1)(C) plea agreement can be excused or "cured" by surrounding advocacy or contextual "bookending," in conflict with Santobello v. New York, 404 U.S. 257 (1971), and the approaches of the Second, Third, Fifth, Sixth, and Eighth Circuits?

II. Whether, in a Rule 11(c)(1)(C) case, the government satisfies its obligation to present a "united front" for the agreed cap when it affirmatively states to the court that it cannot oppose a higher sentence outside the agreement, thereby undermining the accept or reject structure of Rule 11(c)(1)(C)?

III. Whether a court of appeals applying plain error review under Puckett v. United States, 556 U.S. 129 (2009), may deny relief for an explicit plea breach by pointing to aggravating facts and hypothesizing the same sentence would have been imposed, in conflict with Santobello's holding that the remedy does not turn on whether the sentencing judge would have imposed the same term absent the breach?

Question Presented (AI Summary)

Whether an explicit breach of a Rule 11(c)(1)(C) plea agreement can be excused by surrounding advocacy in conflict with Santobello v. New York, and whether courts of appeals may deny relief by hypothesizing the same sentence would have been imposed absent the breach

Docket Entries

2026-03-31
Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due May 22, 2026)

Attorneys

Eddy Reyes
Marisa ConroyLaw Office of Marisa L. D. Conroy, Petitioner
United States
D. John SauerSolicitor General, Respondent