How did appellate courts initially react to plea-bargained convictions during the American Civil War?

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Salem witch trial — Plea bargaining A scene of the trials in Salem Village, Massachusetts Bay Colony, hand-colored engraving.

During the American Civil War, appellate courts began to encounter cases involving plea-bargained convictions for the first time.1

These courts initially reacted with surprise, mirroring the skepticism previously expressed by trial court judges when they first encountered the practice. Consequently, appellate courts sometimes reversed convictions that were based on these bargains, as the practice had not yet gained full acceptance within the judicial system.1