U.S. v. Adigun

Ct. of Appeals lacked jurisdiction to consider defendant’s appeal of Dist. Ct.’s pre-trial order denying his motion to suppress drugs seized from his vehicle where defendant entered guilty plea on day of trial without reserving said issue for appeal. Entry of unconditional guilty plea precludes challenge to denial of motion to suppress since said guilty plea constitutes waiver of any non-jurisdictional defect occurring prior to plea. Ct. rejected defendant’s claim that no waiver occurred because he subjectively believed that he had preserved his right to appeal instant suppression ruling.