Forfeiture for others' gains
Cid v. United States
In brief
The Supreme Court sent Cid’s case back for reconsideration under Hunter, without deciding whether her forfeiture order can stand.
- Where it stands
- Decided
Decided · November 9, 2026
- What it’s about
- Cid's $6,554,250 forfeiture was based on proceeds the district court said she jointly obtained with co-conspirators; the Eleventh Circuit threw out her appeal under her plea-agreement waiver.
- Who it affects
- The Eleventh Circuit must reconsider Cid’s appeal in light of Hunter, but the Supreme Court did not decide whether her forfeiture can stand.
Summary: written with AI from the case record.
What it's about
The Supreme Court granted review, wiped out that judgment (vacated it), and sent the case back (remanded) to reconsider under Hunter, without deciding whether the forfeiture was lawful.
The district court ordered $6,554,250 in forfeiture based on proceeds it said Cid jointly obtained with co-conspirators. The Eleventh Circuit threw out Cid’s appeal under the waiver in her plea agreement.
The case concerns whether a plea-agreement appeal waiver can block review of a criminal forfeiture order that includes proceeds a defendant did not personally obtain.
Question presented
Whether, in light of Hunter, an appeal waiver may be enforced to bar review of a criminal forfeiture order imposing joint-and-several liability for proceeds the defendant did not obtain—a form of forfeiture that 18 U.S.C. § 982(a)(2)(A), as construed in Honeycutt v. United States, does not authorize.
What the Court decided
Holding
Motion to proceed in forma pauperis and petition for a writ of certiorari granted. Judgment vacated and case remanded for further consideration in light of Hunter v. United States, 608 U. S. 713 (2026).
- Result
- Vacated
What's next
The Eleventh Circuit will reconsider the case in light of Hunter v. United States.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Brief added: Petition
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.