United States v. Bynum

CourtCourt of Appeals for the Tenth Circuit
DecidedOctober 2, 2024
Docket24-5061
StatusUnpublished

This text of United States v. Bynum (United States v. Bynum) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Bynum, (10th Cir. 2024).

Opinion

Appellate Case: 24-5061 Document: 44-1 Date Filed: 10/02/2024 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT October 2, 2024 _________________________________ Christopher M. Wolpert Clerk of Court UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 24-5061 (D.C. No. 4:23-CR-00091-JDR-1) AMANDA NICOLE BYNUM, (N.D. Okla.)

Defendant - Appellant. _________________________________

ORDER AND JUDGMENT* _________________________________

Before HARTZ, EBEL, and BACHARACH, Circuit Judges. _________________________________

Pursuant to a plea agreement, appellant Amanda Nicole Bynum pled guilty to

child neglect and enabling child abuse in Indian Country and was sentenced to 120

months’ imprisonment followed by five years of supervised release. Under the terms

of her plea agreement, Bynum waived her right of direct appeal unless the sentence

imposed exceeded the statutory maximum for her crimes, which is life in prison. She

nonetheless filed the instant appeal challenging her conviction and sentence. The

government has moved to enforce the appellate waiver in the plea agreement under

United States v. Hahn, 359 F.3d 1315 (10th Cir. 2004) (en banc).

* This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 24-5061 Document: 44-1 Date Filed: 10/02/2024 Page: 2

In evaluating whether to enforce an appellate waiver under Hahn, we ask

“(1) whether the disputed appeal falls within the scope of the waiver of appellate

rights; (2) whether the defendant knowingly and voluntarily waived his appellate

rights; and (3) whether enforcing the waiver would result in a miscarriage of justice.”

359 F.3d at 1325. Bynum concedes this appeal falls within the scope of her waiver

but argues the waiver was not knowing and voluntary and that enforcing it would

result in a miscarriage of justice.

Knowing and Voluntary Waiver. Two factors are especially relevant to our

knowing-and-voluntary analysis—first, the language of the plea agreement itself and

second, the adequacy of the plea colloquy required by Federal Rule of Criminal

Procedure 11. Id. Bynum does not challenge the adequacy or clarity of the plea

agreement’s waiver language. Nor could she. It plainly states, “[t]he defendant

waives rights under 28 U.S.C. § 1291 and/or 18 U.S.C. § 3742(a) to directly appeal

the conviction and sentence . . .; except that the defendant reserves the right to appeal

from a sentence that exceeds the statutory maximum.” R. vol. 1 at 69. Moreover,

Bynum explicitly acknowledged that her “counsel ha[d] explained her appellate and

post-conviction rights; that [she understood] her rights; and that [she] knowingly and

voluntarily waive[d] those rights.” Id. at 70 (emphasis added).

Bynum’s argument centers on the adequacy of the Rule 11 colloquy.

Specifically, Bynum claims she has a below-average IQ score of 68 and was “on and

off unspecified medication to treat undisclosed psychiatric disorders” at the time of

her plea. Opp. to Mot. to Dismiss at 7. Given these circumstances, Bynum argues

2 Appellate Case: 24-5061 Document: 44-1 Date Filed: 10/02/2024 Page: 3

her appellate waiver could not have been knowing and voluntary. She claims that

“[h]ad [she] fully understood the impact of her plea as well as the appellate waiver it

contained, she may have chosen to proceed to trial or enter her plea in the absence of

a plea agreement to avoid the appeal waiver provision.” Id. We are not persuaded.

First, the transcript of the plea colloquy eliminates any concern over the

medication issue. During the colloquy, Bynum reported she had previously taken

medication for depression and anxiety but was not on those medications at that time.

The court followed up with defense counsel to clarify that Bynum was not currently

being treated for any mental health issues. And it went on to ensure Bynum

understood the proceedings in her current unmedicated state, asking Bynum, “[s]o

does the absence of – the fact that you’re not on those medications, do you feel like

you understand what’s going on here today?” R. vol. 3 at 23. Bynum answered,

“Yes, ma’am.” Id. Bynum further assured the court that being unmedicated was not

affecting her “ability to understand and think clearly.” Id. at 23-24. And she has

offered no evidence that suggests her comprehension was compromised by the

absence of psychiatric medication in her system.

Second, even accepting Bynum’s unsupported claim about her below-average

IQ score, she cites no authority for her argument that such a measurement, standing

alone, negated her competency to waive her appellate rights.1 We are aware of no

1 We note Bynum has not challenged the validity of her guilty plea. Rather, her competency argument is focused exclusively on that part of the plea agreement in which she relinquished her appellate rights. 3 Appellate Case: 24-5061 Document: 44-1 Date Filed: 10/02/2024 Page: 4

such authority. The well-settled standard for evaluating a criminal defendant’s

competency is “whether the defendant has sufficient present ability to consult with

his lawyer with a reasonable degree of rational understanding and has a rational as

well as factual understanding of the proceedings against him.” Godinez v. Moran,

509 U.S. 389, 396 (1993) (internal quotation marks omitted); see also id. at 398-99

(holding the competency standard is the same whether the defendant pleads guilty or

stands trial). In reviewing competency issues, we are mindful of the district court’s

superior vantage point from which to assess the defendant’s understanding of the

proceedings. See United States v. Landa-Arevalo, 104 F.4th 1246, 1254 (10th Cir.)

(noting “a defendant’s behavior and demeanor play central roles in a competency

determination”), petition for cert. filed, ___ U.S. ___ (Sept. 24, 2024).

Bynum has given us no reason to second-guess the district court’s Rule 11

colloquy or ultimate decision to accept her guilty plea pursuant to a plea agreement

that included an appeal waiver. Bynum’s counsel informed the court she had read the

plea agreement and plea petition to her client “word for word and also explained the

terms that weren’t familiar to [Bynum] and the concepts related to the plea

agreement.” R. vol. 3 at 22. Bynum’s counsel stated she’d had no “special difficulty

communicating with Ms. Bynum,” and believed Bynum understood the proceedings

and was competent to proceed. Id. at 24. Bynum confirmed the truth of these

statements and told the court she was satisfied with her counsel’s representation.

Aside from claiming she has a below-average IQ, Bynum offers nothing to counter

this evidence. We thus conclude she has failed to demonstrate her waiver was not

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Related

Godinez v. Moran
509 U.S. 389 (Supreme Court, 1993)
United States v. Edgar
348 F.3d 867 (Tenth Circuit, 2003)
United States v. Hahn
359 F.3d 1315 (Tenth Circuit, 2004)
United States v. Landa-Arevalo
104 F.4th 1246 (Tenth Circuit, 2024)

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