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Brady v. United States

Law Dictionary

Law Dictionary

Featuring Black's Law Dictionary 2nd Ed.
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Criminal Procedure keyed to Weinreb

Citation. Brady v. United States, 397 U.S. 742, 90 S. Ct. 1463, 25 L. Ed. 2d 747, 1970 U.S. LEXIS 45 (U.S. May 4, 1970)

Brief Fact Summary. The Petitioner plead guilty to kidnapping after his co-defendant decided to confess and testify against him. The voluntariness of the Petitioner’s plea was at issue.

Synopsis of Rule of Law. “[There is] no requirement in the Constitution that a defendant must be permitted to disown his solemn admissions in open court that he committed the act with which he is charged simply because it later develops that the State would have had a weaker case than the defendant had thought or that the maximum penalty then assumed applicable has been held inapplicable in subsequent judicial decisions.”

Facts. The Petitioner, in 1959, was charged with violating 18 U.S.C. Section: 1201(a), a statute prohibiting kidnapping. Pursuant to the statute, since the individual the Petitioner kidnapped eventually died, the Petitioner could have received the death penalty. The petitioner initially plead not guilty. After learning that his co-defendant confessed to the authorities, would plead guilty and be available to testify against him, the Petitioner decided to plea guilty. Prior to the Petitioner entering his plea, the trial judge questioned him twice about the voluntariness of his plea. The Petitioner was sentenced to fifty years in prison and it was later reduced to thirty.
In 1967, pursuant to 28 U.S.C. Section: 2255, Petitioner sought relief arguing that his guilty plea was not voluntary in that Section:1201 (a) worked to coerce his plea, because his counsel exerted impermissible pressure upon him and “because his plea was induced by representations with respect to reduction of sentence and clemency.”
The District Court of the District of New Mexico denied relief and the Circuit Court affirmed concluding that the District Court’s finding were supported by substantial evidence. Specifically approving of the District Court’s finding that petitioner’s plea of guilty was voluntary.

Issue. Whether “Jackson requires the invalidation of every plea of guilty entered under [Section:1201(a)], at least when the fear of death is shown to have been a factor in the plea[?]”

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