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)

Resources