U.S. v. Combs

Defendant waived his contention that Dist. Ct. erred in failing to address merits of defendant's untimely motion to suppress where defendant subsequently entered into unconditional guilty plea to charge of unlawful possession of firearm. Entry of unconditional guilty plea waives all non-jurisdictional defects arising prior to entry of said plea, and defendant failed to otherwise preserve said issue under Rule 11(a)(2). Ct. rejected govt. stance that absence of conditional guilty plea that preserved suppression issue for appeal is not fatal to Ct. of Appeals acquiring jurisdiction of appeal where, as here, govt. had failed to mention defendant's waiver of suppression issue and addressed merits of said issue in its brief.