Hunter v. United States

When Munson Hunter III (defendant) was charged with 10 counts of bank and wire fraud, he entered a plea agreement, pleading guilty to one count of aiding and abetting wire fraud in exchange for the government dismissing the remaining charges. The agreement included an appeal waiver under which Hunter agreed not to appeal either his conviction or his sentence, which was yet to be determined. It also specified that the agreement’s terms could be modified only by a signed writing. At the subsequent sentencing hearing, the judge sentenced Hunter to 51 months in prison, followed by three years on probation. Over Hunter’s objection, the sentence included a requirement that Hunter take mental-health medications during the probation period. At the close of the hearing, the judge mistakenly told Hunter he had a right to appeal. The prosecutor did not object. Hunter promptly appealed his sentence to challenge the medication requirement. The government sought dismissal, citing the appeal waiver. Hunter argued that the waiver was unenforceable because (1) the sentencing judge’s representation that Hunter could appeal, and the prosecution’s failure to object, voided the waiver; and (2) the disputed aspect of the sentence violated a fundamental due-process liberty interest in freedom from unwanted medication. The Fifth Circuit dismissed the appeal, finding the appeal waiver enforceable. The Supreme Court granted certiorari to address a circuit split regarding when sentencing appeal waivers are unenforceable.