Case Explained: United States v. Butterworth

Court: United States Court of Appeals for the Tenth Circuit Filed: 2026-06-25 Docket: 1:24-CR-00039-GPG-1) The tenth-circuit granted the government’s motion to enforce an appeal waiver and dismissed the defendant’s appeal. The court applied the three-part standard from *United States v. Hahn*, which requires that the appeal fall within the scope of the waiver, that the waiver was made knowingly and voluntarily, and that enforcement would not result in a miscarriage of justice. Although the appeal had been abated pending the Supreme Court’s decision in *Hunter v. United States*, the court lifted the abatement after *Hunter* confirmed that a district court’s statement at sentencing regarding a defendant’s right to appeal does not negate the enforceability of an otherwise valid waiver. Because the defendant conceded the waiver was enforceable under existing precedent and the new ruling did not alter that standard, the court enforced the waiver and dismissed the case. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.