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Hunter v. United States
Opinion: https://www.supremecourt.gov/opinions/25pdf/24-1063new_l5gm.pdf
Case background
Munson Hunter III was charged with 10 counts of bank and wire fraud for a
years-long scheme that cost various financial institutions about half a
million dollars. He entered into a written plea agreement with the
Government, pleading guilty to one count of aiding and abetting wire fraud in
exchange for dismissal of the remaining nine charges and a promise not to
prosecute him for the described conduct. The agreement included an appeal
waiver covering both his conviction and his sentence, and provided that any
modification of its terms had to be in writing and signed by all parties. At
sentencing, the District Court imposed 51 months in prison followed by three
years of supervised release, including a condition — over Hunter’s objection
— that he take all mental-health medications prescribed by his treating
physician. At the close of the hearing the court told Hunter he had “a right
to appeal,” and the prosecutor did not object. Hunter appealed the medication
condition, and the Government sought dismissal based on the appeal waiver. The
Court of Appeals for the Fifth Circuit dismissed the appeal, holding that
under Circuit precedent appeal waivers are enforceable except in two
circumstances: when the waiver was tainted by ineffective assistance of
counsel, and when the sentence exceeded the statutory maximum.
Questions Presented
(1) Whether the only permissible exceptions to a general appeal waiver are for claims of ineffective assistance of counsel or that the sentence exceeds the statutory maximum.
(2) Whether an appeal waiver applies when the sentencing judge advises the defendant that he has a right to appeal and the government does not object.
Holding
An agreement not to appeal a sentence is unenforceable when it would result
in a miscarriage of justice — meaning, when it would leave in place the kind
of egregious error that would bring the judicial system into disrepute.
Because courts must approve and implement appeal waivers, the standard for
enforcing them implicates the integrity of the judiciary, not just the
interests of the parties. The miscarriage-of-justice limit sets a high bar:
the error must be obvious, not one a judge could reasonably make, and of a
type that would undermine public confidence in the judiciary. Ordinary
mistakes in applying sentencing law cannot cancel an appeal waiver. The Court
declined to decide in the first instance whether Hunter’s challenge to the
mandatory-medication condition meets that standard, and vacated and remanded
for the Fifth Circuit to decide that question.
The Court
Justice Kagan delivered the opinion of the Court, in which Chief Justice
Roberts and Justices Alito, Sotomayor, Gorsuch, Kavanaugh, Barrett, and
Jackson joined. Justice Gorsuch filed a concurring opinion, in which Justices
Sotomayor and Jackson joined. Justice Kavanaugh filed a concurring opinion,
in which Justices Alito and Barrett joined. Justice Barrett filed a concurring
opinion. Justice Thomas filed a dissenting opinion.
What this episode contains
This episode is an AI-narrated reading of the majority opinion in
Hunter v. United States, written by Justice Kagan.
AI disclosure: The voice in this episode is AI-generated, using a machine
learning model styled to loosely resemble the authoring justice. Tone,
inflection, pacing, and emphasis are artifacts of the model and should not be
attributed to Justice Kagan. The text being read is the Court’s published
majority opinion, lightly adapted to improve readability for the spoken format.
View all episodes
By So OrderedOpinion: https://www.supremecourt.gov/opinions/25pdf/24-1063new_l5gm.pdf
Case background
Munson Hunter III was charged with 10 counts of bank and wire fraud for a
years-long scheme that cost various financial institutions about half a
million dollars. He entered into a written plea agreement with the
Government, pleading guilty to one count of aiding and abetting wire fraud in
exchange for dismissal of the remaining nine charges and a promise not to
prosecute him for the described conduct. The agreement included an appeal
waiver covering both his conviction and his sentence, and provided that any
modification of its terms had to be in writing and signed by all parties. At
sentencing, the District Court imposed 51 months in prison followed by three
years of supervised release, including a condition — over Hunter’s objection
— that he take all mental-health medications prescribed by his treating
physician. At the close of the hearing the court told Hunter he had “a right
to appeal,” and the prosecutor did not object. Hunter appealed the medication
condition, and the Government sought dismissal based on the appeal waiver. The
Court of Appeals for the Fifth Circuit dismissed the appeal, holding that
under Circuit precedent appeal waivers are enforceable except in two
circumstances: when the waiver was tainted by ineffective assistance of
counsel, and when the sentence exceeded the statutory maximum.
Questions Presented
(1) Whether the only permissible exceptions to a general appeal waiver are for claims of ineffective assistance of counsel or that the sentence exceeds the statutory maximum.
(2) Whether an appeal waiver applies when the sentencing judge advises the defendant that he has a right to appeal and the government does not object.
Holding
An agreement not to appeal a sentence is unenforceable when it would result
in a miscarriage of justice — meaning, when it would leave in place the kind
of egregious error that would bring the judicial system into disrepute.
Because courts must approve and implement appeal waivers, the standard for
enforcing them implicates the integrity of the judiciary, not just the
interests of the parties. The miscarriage-of-justice limit sets a high bar:
the error must be obvious, not one a judge could reasonably make, and of a
type that would undermine public confidence in the judiciary. Ordinary
mistakes in applying sentencing law cannot cancel an appeal waiver. The Court
declined to decide in the first instance whether Hunter’s challenge to the
mandatory-medication condition meets that standard, and vacated and remanded
for the Fifth Circuit to decide that question.
The Court
Justice Kagan delivered the opinion of the Court, in which Chief Justice
Roberts and Justices Alito, Sotomayor, Gorsuch, Kavanaugh, Barrett, and
Jackson joined. Justice Gorsuch filed a concurring opinion, in which Justices
Sotomayor and Jackson joined. Justice Kavanaugh filed a concurring opinion,
in which Justices Alito and Barrett joined. Justice Barrett filed a concurring
opinion. Justice Thomas filed a dissenting opinion.
What this episode contains
This episode is an AI-narrated reading of the majority opinion in
Hunter v. United States, written by Justice Kagan.
AI disclosure: The voice in this episode is AI-generated, using a machine
learning model styled to loosely resemble the authoring justice. Tone,
inflection, pacing, and emphasis are artifacts of the model and should not be
attributed to Justice Kagan. The text being read is the Court’s published
majority opinion, lightly adapted to improve readability for the spoken format.