Seventh Circuit -- USA v. Adebisi Adigun

Even absent colloquy informing deft of the waiver, a guilty plea without a written agreement preserving certain grounds for appeal operates as an unconditional guilty plea waiving all ex ante non-jurisdictional grounds for appeal.

This is jurisdictional - open question as to whether government can waive it, but as govt hasn't in this case, court has no subject matter jurisdiction to hear a suppression challenge.

Courts reasons for denying downward variance make erroneous imposition of old statutory minimum sentence harmless error.

USA v. Adebisi Adigun