Supreme Court Sides With Criminal Defendant in Forced Medication Case

The U.S. Supreme Court ruled on June 18 that a Texas man may challenge a compulsory medication order in his sentence even though he waived his right to appeal in a plea agreement with prosecutors.

The new ruling gives criminal defendants who have signed appeal waivers during the plea bargaining process a limited opening to challenge sentencing conditions they believe are unconstitutional or outrageous.

Justice Elena Kagan wrote the court’s 8–1 opinion in Hunter v. United States, holding it would be unfair not to allow the man to appeal.

Justice Clarence Thomas dissented.

The petitioner, Munson P. Hunter III, was convicted in federal district court in Texas in February 2024 of aiding and abetting wire fraud. He was sentenced to four years and three months in prison, followed by three years of supervised release and restitution of $235,438.

According to the government, between 2013 and 2023, Hunter used fraudulently acquired Social Security numbers to open 14 bank accounts, obtain at least 18 credit cards, and file for loans from the Small Business Administration. These fraudulent acts ended up costing others almost $500,000.

Hunter signed a plea agreement that provided he was voluntarily waiving the right to appeal except to raise a claim of ineffective assistance of counsel or on collateral review. Collateral review refers to a legal proceeding challenging a court ruling outside the standard appeal process.

At the May 2024 sentencing hearing, Hunter, who suffers from anxiety and depression, objected to a proposed special condition of supervised release that stipulated he “must take all mental health medications that are prescribed by [his] treating physician,” according to his April 2025 petition.

The petition said he told the court at that time that he didn’t drink, use drugs, or “even curse,” and that he didn’t want to be “forced to medicate.” The court imposed the medication requirement, advising Hunter that he had a right to appeal.

Hunter appealed the medication order portion of the sentence to the U.S. Court of Appeals for the Fifth Circuit.

In his petition, Hunter argued that the order “infringes on [his] fundamental due process liberty interest in being free of unwanted mental health medication.”

He said that the appeal waiver did not take away his constitutional claim, or in the alternative, that the sentencing judge’s assurance that he had a right to appeal, “combined with the government’s acquiescence, should void the appeal waiver.”

The Fifth Circuit threw out the case in December 2024, saying his appeal was precluded by the appeal waiver that he previously signed.

“The district court’s statement at the sentencing hearing that Hunter had a right to appeal did not impact the validity of the appeal waiver,” the circuit court stated.

During the oral argument before the Supreme Court on March 3, U.S. Department of Justice (DOJ) attorney Zoe Jacoby urged the justices to dismiss Hunter’s case.

“Knowing and voluntary presentence appeal waivers are enforceable bargains, and no doctrine of contract law calls for a different result based on the subsequent sentence that the defendant receives,” she said.

Hunter was asking the court to create new rules that would limit when “knowing and voluntary” waivers may be enforced, but he hasn’t given the court any clear, workable way to decide which waivers should be allowed and which shouldn’t, Jacoby said.

If the justices were to accept his argument, it would unleash a flood of litigation that “would essentially eliminate all appeal waivers,” she said.

Majority Opinion

In her opinion, Kagan did not rule on the validity of the medication order itself, but said not allowing Hunter to appeal the order would be unjust.

“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.”

“If a court always carries out those waivers—no matter the kind or degree of error tainting a sentence—the judicial system’s integrity may come into question,” Kagan said.

She noted that the Fifth Circuit did not address the miscarriage-of-justice exception but will now have to do so on remand.

The Supreme Court vacated the circuit court’s ruling and sent it back to that court “for further proceedings consistent with this opinion.”

Justice Neil Gorsuch filed a concurring opinion, which Justices Sonia Sotomayor and Ketanji Brown Jackson joined.

“In our times, the jury trial has given way to a conveyor belt of plea bargains,” and the Supreme Court “has often condoned those practices or let them pass in silence,” Gorsuch said.

“Today, the Court begins to correct course. It rules that prosecutors may not always leverage their plea-bargaining power to induce a defendant to forego the right to contest his sentence on appeal,” he said.

Justice Brett Kavanaugh filed a one-paragraph concurrence, saying the court has appropriately set a “‘high bar’ for the miscarriage-of-justice exception to render an appeal waiver unenforceable.”

He said he took exception to Gorsuch’s apparent understanding of the exception.

“As I read it, his concurring opinion would set a lower bar for the miscarriage-of-justice exception than the Court’s opinion does. In my view, therefore, the concurrence may not be entirely consistent with the Court’s opinion.”

Kavanaugh’s opinion was joined by Justices Samuel Alito and Amy Coney Barrett.

In his dissent, Thomas said the majority had created a “free-floating ‘miscarriage-of-justice’ exception,” without citing any constitutional, statutory, or precedential authority to support it.

“Our duty is to apply the law, not to make it,” he said.

In an opinion concurring with the majority, Barrett said despite her support for the majority position, she shared Thomas’s skepticism that “the Supreme Court possesses an inherent, supervisory authority over inferior federal courts.”

The Cato Institute, which filed a brief in the case, hailed the new ruling for rejecting “the pernicious practice of allowing so-called ‘appeal waivers’ in plea agreements to shield unconstitutional sentences from judicial review.”

Constitutional protections “are not mere bargaining chips,” and no criminal defendant “can meaningfully ‘waive’ the right to challenge a sentence whose illegality he cannot anticipate in advance,” the libertarian think tank said in a statement.

The Epoch Times reached out to the DOJ for comment, and no reply was received by publication time.