Kareem Muhammad v. United States

The overwhelming majority of criminal cases are resolved by plea bargaining. However, how these agreements are interpreted lacks uniformity in the court of appeals. In this case concerning a breach of a plea agreement, the court of appeals strictly limited its review to the “four corners” of the agreement. This approach departs from those of other courts of appeals who do not so limit their review of the plea agreement and instead consider the parties’ conduct and expectations. The questions presented are:

1. Whether construction of a plea agreement’s terms is limited to review of the agreement’s language and cannot take into consideration circumstances, such as the parties’ conduct and expectations, outside the agreement’s terms?

2. Whether the examination of circumstances outside the “four corners” of the plea agreement should be conducted to establish what a defendants’ reasonable expectation of the scope of the plea agreement’s terms?