United States of America v. Kyrie Rashaud Thompson

Greenbelt, Maryland criminal defense lawyer represented the Defendant charged with kidnapping and witness tampering.



Kyrie Rashaud Thompson pleaded guilty to kidnapping and attempted witness

tampering without a plea agreement. Despite his unconditional plea, Thompson now seeks

to challenge the district court's denial of his earlier motion to suppress, as he claims the

district court misadvised him about the scope of his appellate rights. He also challenges

his sentence based on alleged discrepancies between the oral and written conditions of his

supervised release. Finding no error, we affirm the district court court's judgment and

dismiss the portion of Thompson's appeal challenging the district court's denial of his

motion to suppress.



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"[A] guilty plea must be both knowing and voluntary” because it "constitutes a

waiver of three constitutional rights: the right to a jury trial, the right to confront one's

accusers, and the privilege against self-incrimination.” Parke v. Raley, 506 U.S. 20, 28–

29 (1992) (citing Boykin v. Alabama, 395 U.S. 238, 242–43 (1969)). Through a plea

agreement, a defendant may also waive their right to appeal. United States v. Manigan,

592 F.3d 621, 627 (4th Cir. 2010) (citing United States v. Poindexter, 492 F.3d 263, 267–

68 (4th Cir. 2007)). But although "a guilty plea [also] results in the defendant's loss of any

meaningful opportunity he might otherwise have had to challenge the admissibility of

evidence obtained in violation of the Fourth Amendment[,] . . . a guilty plea is [not] a

'waiver' of antecedent Fourth Amendment claims[.]” See Haring v. Prosise, 462 U.S. 306,

320–21 (1983) ("The defendant's rights under the Fourth Amendment are not among the

trial rights that he necessarily waives when he knowingly and voluntarily pleads guilty.”).

Instead, "a counseled plea of guilty is an admission of factual guilt so reliable that,

where voluntary and intelligent, it quite validly removes the issue of factual guilt from the

case.” Id. at 321 (quoting Menna v. New York, 423 U.S. 61, 62–63 n.2 (1975)). In doing

so, a valid guilty plea "renders irrelevant—and thereby prevents the defendant from

appealing—the constitutionality of case-related government conduct that takes place

before the plea is entered.” Class v. United States, 583 U.S. 174, 182 (201.

Affirmed