No. 25-5154

Elijah Muhammad v. United States

Lower Court: Fifth Circuit
Docketed: 2025-07-21
Status: Denied
Type: IFP
Response WaivedIFP
Tags: appellate-review breach-of-contract criminal-procedure due-process four-corners-doctrine plea-agreement
Key Terms:
DueProcess CriminalProcedure JusticiabilityDoctri
Latest Conference: 2025-09-29
Related Cases: 25-5211 (Vide)
Question Presented (AI Summary)

Whether a court should only look at the 'four corners' of the plea agreement language when determining whether a breach occurred, or should also consider circumstances and events outside the agreement that are relevant to the reasonable understanding and expectations of the parties?

Question Presented (OCR Extract)

The overwhelming majority of criminal cases are resolved by plea bargaining. However, how these agreements are interpreted lacks uniformity in the federal appellate courts . In this case concerning a breach of a plea agreement, the court of appeals strictly limited its review to the “four corners” of the agreement. This approach departs from those of other courts of appeals who do not so limit their review of the plea agreem ent and instead consider the parties’ conduct and expectations. The questions prese nted are: 1. Whether a court should only look at the “four corners” of the plea agreement language when determining whether a breach of the plea agreement occurred; as opposed to also looking at circumstances and events outside of the four corners that are relevant to the reasonable understanding and expectations of the agreement ? 2. Weather t he Fifth Circuit’s newly established “four corners” doctrine, led to a deprivation of due process of the Petitioner because a reasonable person in his position would have thought the plea agreement for his drug case covered his conduct surrounding a sex trafficking case ?

Docket Entries

2025-10-06
Petition DENIED.
2025-07-31
DISTRIBUTED for Conference of 9/29/2025.
2025-07-29
Waiver of United States of right to respond submitted.
2025-07-29
Waiver of right of respondent United States to respond filed.
2025-07-17
Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due August 20, 2025)

Attorneys

Elijah Muhammad
Matthew Joseph SmidThe Law Office of Matthew J . Smid PLLC, Petitioner
Matthew Joseph SmidThe Law Office of Matthew J . Smid PLLC, Petitioner
United States
D. John SauerSolicitor General, Respondent
D. John SauerSolicitor General, Respondent