United States of America v. Aaron Olson

United States Court of Appeals
For the Eighth Circuit
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No. 24-1466
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United States of America
Plaintiff - Appellee
v.
Aaron Olson
Defendant - Appellant
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Appeal from United States District Court
for the Northern District of Iowa - Eastern
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Submitted: September 12, 2024
Filed: September 20, 2024
[Unpublished]
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Before KELLY, GRASZ, and STRAS, Circuit Judges.
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PER CURIAM.
When Aaron Olson pleaded guilty to child-pornography charges, see 18
U.S.C. § 2252A(a)(5)(B), (b)(2), he expressly waived his right to receive a sentence
reduction. See id. § 3582(c)(2). Several years later, the district court1 raised the
1 The Honorable C.J. Williams, Chief Judge, United States District Court for
the Northern District of Iowa.

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issue on its own and denied relief. His counsel, who seeks to withdraw, suggests
that he was eligible for one. Olson makes a similar point and challenges the waiver
itself in a pro se brief.
We conclude that the plea agreement forecloses their arguments. See United
States v. Scott, 627 F.3d 702, 704 (8th Cir. 2010) (reviewing the validity of a waiver
de novo); United States v. Andis, 333 F.3d 886, 889–90 (8th Cir. 2003) (en banc)
(explaining that defendants can waive additional statutory rights when they plead
guilty if “each term of [the] agreement” is “entered into knowingly and voluntarily”).
The district court could not have erred by denying a right that Olson had already
“intentional[ly] relinquish[ed].” United States v. Olano, 507 U.S. 725, 733 (1993)
(citation omitted). We accordingly dismiss the appeal and grant counsel permission
to withdraw.
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