The ostrich’s undeserved claim to fame is that it buries its head in the sand instead of facing danger.[1] Parties to litigation sometimes act like this, too.
— Judge O. Rogeriee Thompson of the First Circuit, explaining in the introduction of a recent opinion that by “ignoring [his] plea agreement’s clear waiver of appeal provision fares,” Miguelito Arroyo-Blas, the appellant in U.S. v. Arroyo-Blas, would “fare[] no better . . . than we imagine our proverbial ostrich does when confronted by a predator in the wild.”
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[1] “Not that ostriches really bury their heads in the sand when threatened,” Gonzalez-Servin v. Ford Motor Co., 662 F.3d 931, 934 (7th Cir. 2011), but the image persists. And it suits our purposes well.