The Supreme Court ruled 8-1 on June 18, 2026, in Hunter v. United States, establishing a "miscarriage of justice" exception to appeal waivers in federal criminal plea bargains. The decision vacated the U.S. Court of Appeals for the 5th Circuit's ruling and remanded the case for further consideration.

Justice Elena Kagan wrote the majority opinion, which Chief Justice John Roberts joined. Justice Kagan stated that an appeal waiver is "unenforceable when it would result in a miscarriage of justice." She defined a miscarriage of justice as "the kind of egregious error that would bring the judicial system into disrepute" and "undermine public confidence in the judiciary."

The case originated with Munson Hunter III, who pleaded guilty to fraud in 2024. As part of a plea bargain dismissing nine of ten criminal charges, Hunter waived his right to appeal his conviction or sentence. Hunter stated in court that he understood his sentence had not yet been determined and would be at the judge's discretion. He also stated in court that he "knowingly and voluntarily waives the right to appeal."

The court's probation office recommended that Hunter take all prescribed mental health medications during supervised release. Hunter objected to this condition, stating, "I don't drink. I don't use drugs. ... I don't want to have to be forced to medicate." The sentencing judge imposed the medication condition. Hunter appealed, arguing that compelled medication would violate his constitutional rights. The 5th Circuit dismissed his appeal, ruling that an appeal waiver controls even if a sentence is unconstitutional.

Justice Neil Gorsuch wrote a concurring opinion joined by Justices Sonia Sotomayor and Ketanji Brown Jackson. Justice Gorsuch wrote that "the jury trial has given way to a conveyor belt of plea bargains." Separately, Justice Brett Kavanaugh wrote a concurrence joined by Justices Samuel Alito and Amy Coney Barrett. Justice Barrett also filed a separate concurrence. Justice Clarence Thomas wrote a solo dissent.

Why It Matters

This Supreme Court decision introduces an exception to the general enforceability of appeal waivers in federal criminal plea bargains, which represent a large portion of criminal case resolutions. By allowing for review in cases involving a "miscarriage of justice," the ruling provides a mechanism for defendants to challenge sentences that may contain egregious errors, even if they initially waived their appeal rights. This modification directly impacts how federal courts will handle certain post-conviction appeals stemming from plea agreements.