Santobello v. New York
Santobello v. New York is a pivotal Supreme Court case from 1971 that addressed the integrity of plea-bargaining agreements within the criminal justice system. The case involved Rudolph Santobello, who initially pleaded not guilty to gambling charges but later accepted a plea deal to a lesser offense after negotiations with prosecutors. However, during sentencing, a new prosecutor recommended the maximum penalty, contradicting the agreed-upon terms of the plea bargain. The court ultimately ruled that this breach of the plea agreement undermined the fairness of the plea-bargaining process, asserting that such agreements are binding and must be honored by prosecutors. Chief Justice Warren Burger emphasized the need for safeguards in plea bargaining to protect defendants and ensure justice. The decision reinforced the legitimacy of plea-bargaining in the legal system and established crucial precedents that prevent courts and prosecutors from unilaterally breaking agreements. This case has had a lasting impact on how plea deals are negotiated and upheld, encouraging their use as a means to expedite legal proceedings.
Santobello v. New York
The Case: US Supreme Court ruling on plea bargaining
Date: Decided on December 20, 1971
Significance: In this case, which granted the petitioner the right to either a resentencing or a new trial, the Supreme Court confirmed the binding nature of plea-bargaining agreements made by prosecutors with defendants in criminal proceedings.
In 1969, in New York, Rudolph Santobello was arraigned on two criminal counts of violating state antigambling statutes. At first, Santobello entered a plea of not guilty, but later, after negotiations with his prosecutors, he changed his plea to guilty to a lesser-included charge, which carried a maximum penalty of one year in prison. Between the entering of the new guilty plea and the sentencing, there was a delay of several months, and in the interim Santobello obtained a new defense attorney, who immediately attempted to have the guilty plea removed and certain evidence suppressed. Both motions were denied.
At Santobello’s sentencing, a new prosecutor recommended the maximum penalty of one year in prison. The defense quickly objected, using the argument that the petitioner’s plea-bargaining agreement had stipulated that the prosecution would make no recommendation regarding sentencing. The judge, rejecting the relevancy of what prosecutors claimed they would do, sentenced Santobello to the full one-year term on the grounds that he was a seasoned and habitual offender. Subsequently, the Appellate Division of the Supreme Court of the State of New York unanimously upheld the conviction.
The US Supreme Court found that the prosecution had breached the plea-bargaining agreement and remanded the case to the state court to determine whether the circumstances required only resentencing before a different judge or whether the petitioner should be allowed to withdraw his guilty plea and be granted a new trial on the two counts as originally charged. The fact that the breach in the plea-bargaining agreement was inadvertent was deemed irrelevant, as was the sentencing judge’s claim that he was not influenced by the prosecutor’s recommendation. Chief Justice Warren E. Burger, in the court's ruling, argued that the plea-bargaining procedure in criminal justice "must be attended by safeguards to ensure the defendant what is reasonably due in the circumstances." Therefore, any agreement made in the plea-bargaining process, because it is part of the inducement used to encourage a plea of guilty, constitutes "a promise that must be fulfilled."
In its decision in Santobello, the Supreme Court both confirmed its formal recognition of plea bargaining, first granted in Brady v. United States (1970), and established its binding nature. Although in later decisions it would review and somewhat modify its position, as, for example, in Mabry v. Johnson (1984), it established an extremely important principle: that prosecutors and courts could not unilaterally renege on promises made in plea-bargaining agreements. The Santobello decision had the effect of encouraging wider use of the plea-bargaining process, an important aid in expediting justice.
Bibliography
Fisher, George. Plea Bargaining’s Triumph: A History of Plea Bargaining in America. Stanford, Calif.: Stanford University Press, 2003.
Rosett, Arthur I. Justice by Consent: Plea Bargains in the American Courthouse. Philadelphia: Lippincott, 1976.
"Santobello v. New York." FindLaw. FindLaw, 2016. Web. 27 May, 2016.
"Santobello v. New York." Oyez. Chicago-Kent College of Law at Illinois Tech, n.d. Web. 27 May, 2016.
Vogel, Mary E. Coercion to Compromise: Social Conflict and the Emergence of Plea Bargaining, 1830-1920. Rev. ed. New York: Oxford University Press, 2005.