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Brady v. United States | 397 U.S. 742 (1970)
The U.S. Constitution guarantees the right to a jury trial. To safeguard this important right, criminal defendants waiving this right must do so voluntarily and knowingly. In Brady versus United States, the Supreme Court considered whether a guilty plea, made in part to avoid a harsher sentence, remains voluntary and knowing if the sentencing scheme at issue is later found to be unconstitutional.
In 1959, Robert Brady was charged with kidnapping. Under the federal kidnapping statute, 18 U.S.C. § 1201(a), the maximum penalty of death could only be imposed by a jury, not a judge. Brady initially pleaded not guilty to the charge. The judge indicated an unwillingness to hear Brady’s case without a jury, and thus Brady didn’t pursue waiver of his rights to a jury trial as a means to avoid the death penalty. Once Brady learned that his codefendant had confessed to the crime and was willing to testify against him, Brady changed his plea to guilty to the kidnapping charges. The judge accepted his guilty plea and questioned Brady twice regarding the voluntary nature of his decision. Brady was sentenced to fifty years in prison, which was later reduced to thirty years. Throughout the entire process, Brady was represented by competent counsel.
In 1968, the United States Supreme Court issued a decision in United States versus Jackson holding that a portion of the federal kidnapping statute was unconstitutional because it permitted only a jury to impose the death penalty. The death penalty provision improperly required a defendant to risk the possibility of a death sentence in order to exercise the defendant’s constitutional right to a jury trial. The Court upheld the statute, but struck down the death penalty provision that had been the basis for Brady’s guilty plea.
In 1967, Brady sought review before the U.S. District Court of New Mexico, arguing that his plea was coerced because of the possibility of the death penalty if he pursued a jury trial. The court denied relief, finding that Brady’s plea was voluntary and knowing and concluded that the kidnapping statute was constitutional. The Tenth Circuit Court of Appeals affirmed. The Supreme Court granted cert.
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