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Brady v. United States
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Brady v. United States | |
Court | Supreme Court of the United States |
---|---|
Citation | 397 U.S. 742 |
Date decided | May 4, 1970 |
Appealed from | 10th Circuit |
Reaffirmed | United States v. Jackson, (1968) |
Facts
- In 1959, Brady was charged with kidnapping.
- At first, Brady pleaded, "Not guilty."
- Later, Brady found out that his co-defendant had pleaded, "guilty!" His co-defendant was willing to testify against Brady.
- Next, Brady changed his plea to "guilty."
- Brady was eventually sentenced to 30 years in prison.
Procedural History
Brady sought a review before the federal court in New Mexico arguing that his guilty plea was coerced.
Brady lost.Issues
Is a voluntary & knowing guilty plea, entered to avoid the risk of the death penalty being imposed by a jury, a coerced plea?
Holding
No. Voluntary & knowing guilty pleas aren't coerced if made to avoid the possibility of the harsher sentencing following a trial.
Judgment
Affirmed
Reasons
Byron White: The decision in Jackson didn't change Brady's voluntary & knowing waiver of his right to a jury trial.
Rule
18 U.S. Code ยง 1201 - Kidnapping : only a jury may impose the death penalty for kidnapping (as of 1960)