Brady v. United States
"Brady v. United States" is a significant Supreme Court case centered around the validity of guilty pleas within the context of plea bargaining. In 1959, Robert M. Brady, facing a kidnapping charge that involved a victim's death, changed his plea from innocent to guilty after his co-defendant pleaded guilty and agreed to testify against him. Brady later argued that his plea was coerced by the death penalty provisions of the Federal Kidnapping Act. The case reached the U.S. Supreme Court, which upheld the lower court's ruling that Brady's plea was voluntary. This decision emphasized that guilty pleas do not inherently violate the Fifth Amendment, even if influenced by the potential for severe penalties. The ruling affirmed the legal standing of plea bargaining, a practice that resolves a significant majority of criminal cases in the United States, facilitating quicker justice while allowing for reduced charges and penalties. The case illustrates the complexities and implications of plea bargaining in the American legal system, highlighting both its practical benefits and the criticisms it faces.
On this Page
Brady v. United States
The Case: U.S. Supreme Court ruling on plea bargaining
Date: Decided on May 4, 1970
Significance: In this decision the Supreme Court first acknowledged the validity of plea bargaining, asserting that it offered a “mutuality of advantage” for both the defendant and the state.
In 1959, Robert M. Brady, a defendant in a kidnapping case that involved the death of the victim, changed a plea of innocent to guilty when a codefendant in the case pleaded guilty and became available as a witness against him. Before admitting the new plea, the judge twice asked Brady if his plea was voluntary. Brady was convicted, but in 1967 he sought a reversal of his conviction in the U.S. District Court for the District of New Mexico, arguing that his guilty plea had not been voluntary. The petitioner argued that the death-penalty provisions of the Federal Kidnapping Act had coerced his plea. The district court denied Brady relief, upholding the constitutionality of the federal statute and arguing that Brady changed his plea because of his codefendant’s confession. The Court of Appeals for the Tenth Circuit affirmed the lower court’s finding.
On certiorari, the U.S. Supreme Court concurred. In the various opinions issued by the Court, it was argued that an earlier case, United States v. Jackson (1968), which struck down the section of the Federal Kidnapping Act under which Brady had originally been tried, did not mandate that every guilty plea previously entered under the statute be deemed invalid, even when the threat of death was a consideration. It was further argued that a guilty plea was not a violation of the Fifth Amendment protection against self-incrimination when it was entered to ensure a lesser penalty than the maximum provided for by a criminal statute. It was also noted that the Fifth Amendment did not bar prosecutors or judges from accepting pleas of guilty to lesser, reduced, or selected charges in order to secure milder penalties. Brady’s guilty plea was held to have been made voluntarily, despite the fact that it was influenced by the death-penalty provision of the statute that United States v. Jackson later declared unconstitutional.
The formal recognition of plea bargaining as a valid procedure for obtaining criminal convictions was very important because plea bargaining has been widely used in the United States, despite the fact that there is no statutory or constitutional basis for it. In fact, almost four-fifths of all convictions in serious state and federal criminal cases are obtained through guilty pleas made to secure either reduced charges or milder punishments. Although the procedure has its critics, it is a practical way of speeding up justice and clearing court dockets. It also mitigates against long pretrial imprisonment and anxiety and protects the public from the criminal activities of habitual offenders who would be free on bail for indefinite periods.
Bibliography
Dripps, Donald A. “Guilt, Innocence, and Due Process of Plea Bargaining.” William & Mary Law Review 57.4 (2016): 1343–1393. Academic Search Complete. Web. 24 May 2016.
Fisher, George. Plea Bargaining’s Triumph: A History of Plea Bargaining in America. Stanford: Stanford UP, 2003.
Hawkins, Eric. “A Murky Doctrine Gets a Little Pushback: The Fourth Circuits Rebuff of Guilty Pleas in United States v. Fisher.” Boston College Law Review 55.6 (2014): 103–114. Legal Collection. Web. 24 May 2016.
Rosett, Arthur I. Justice by Consent: Plea Bargains in the American Courthouse. New York: Lippincott, 1976.
Vogel, Mary E. Coercion to Compromise: Social Conflict and the Emergence of Plea Bargaining, 1830–1920. Rev. ed. New York: Oxford UP, 2005.