In United States v. Yusuf, an opinion consisting of consolidated appeals, the government challenged the sentences of two defendants imposed after guilty pleas. As part of their plea agreements, they each agreed not to argue for a sentence outside the range recommended by the Guidelines. On appeal, the government argued that both defendants breached their plea agreements by seeking sentences below the Guidelines-recommended ranges. Also, one defendant cross-appealed the District Court’s denial of his suppression motion. The Third Circuit agreed with the government, vacated the sentences, and remanded but affirmed the denial of the suppression motion. The Third Circuit analyzed the plea agreements under contract law standards. It determined that the defendants violated their agreements when counsel affirmatively advocated for a sentence below the agreed-upon Guidelines ranges. The Third Circuit then ruled that a police officer did not unnecessarily prolong a traffic stop in violation of the Fourth Amendment.
