Hunter v. United States

Summary

Justice Kagan delivered the Court’s opinion, joined by every Justice except Justice Thomas. The Court held that a knowing and voluntary sentencing-appeal waiver is unenforceable when enforcement would produce a miscarriage of justice: an obvious, egregious sentencing error that would bring the judicial system into disrepute. It also held that the sentencing judge’s erroneous statement about appeal rights neither modified Hunter’s plea agreement nor, through the prosecutor’s silence, waived or forfeited the Government’s enforcement right. The Court vacated and remanded for the Fifth Circuit to apply the miscarriage-of-justice standard without deciding whether Hunter’s mandatory-medication condition satisfied it. Justice Gorsuch, joined by Justices Sotomayor and Jackson, supported the decision, discussed potentially broader applications of the exception, and questioned prospective appeal waivers more generally. Justice Kavanaugh, joined by Justices Alito and Barrett, emphasized the exception’s demanding threshold and disagreed with Gorsuch’s broader reading. Justice Barrett separately grounded the decision in established waiver principles and procedural common law rather than supervisory power. Justice Thomas dissented, arguing that no source of law authorized the exception and that Hunter’s waiver required dismissal of his appeal.