Supreme Court narrows appellate waivers, allows some sentencing appeals
The Supreme Court ruled defendants may appeal sentencing conditions despite appellate waivers under certain conditions.
Why it matters: This decision limits the enforceability of appellate waivers, enabling defendants to challenge sentencing conditions when enforcing waivers would cause a miscarriage of justice. It signals a shift in criminal defense and appellate strategy and sets precedent for future sentencing appeals.
- June 18, 2026: Supreme Court allows some appeals despite appellate waivers.
- Defendant pleaded guilty to fraud involving nearly a decade-long scheme causing $500,000 losses.
- Sentenced to 51 months and a supervised release condition requiring prescribed medication.
- Court ruled exceptions apply when enforcing waivers results in a miscarriage of justice.
- Justices questioned applying contract law rigidly to appellate waivers.
On June 18, 2026, the U.S. Supreme Court issued a significant ruling narrowing the scope of appellate waivers in federal criminal cases. Previously, defendants who pleaded guilty and agreed to appellate waivers were often barred from challenging their sentences on appeal. This ruling allows defendants to appeal certain sentencing conditions despite these waivers, especially when enforcing the waiver would constitute a "miscarriage of justice."
The case involved a defendant convicted of fraud after orchestrating a financial scheme that lasted nearly a decade and caused almost half a million dollars in losses. He was sentenced to 51 months imprisonment and a special supervised release condition requiring him to take prescribed medication for depression and anxiety. Although he had signed an appellate waiver, he later sought to challenge this medical condition imposed on release.
The Court’s reasoning aligns with standards used by several federal courts of appeals, which recognize exceptions to enforcement when upholding waivers would lead to unjust outcomes. According to Richard Cooke, covering the case for SCOTUSblog, some justices expressed misgivings about strictly applying contract law principles to what are essentially plea bargain agreements.
This landmark decision thus impacts criminal defense strategies by preserving an avenue for defendants to appeal problematic sentencing conditions. It also marks a notable shift in appellate law by setting a precedent for future challenges despite appellate waivers, reinforcing the judiciary’s willingness to prevent miscarriages of justice in sentencing.
By the numbers:
- June 18, 2026 — Date of Supreme Court ruling
- 51 months — Defendant's imprisonment sentence
- Nearly $500,000 — Financial losses from defendant's fraud scheme
- Nearly a decade — Duration of defendant's fraudulent activity