Brady v. United States
| Brady v. United States | |
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| Argued November 18, 1969 Decided May 4, 1970 |
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| Full case name | Robert M. Brady v. United States |
| Citations | 397 U.S. 742 (more) |
| Prior history | Appeal from United States Court of Appeals for the Tenth Circuit |
| Holding | |
| The threat of the death penalty is not coercive if the guilty plea is made intelligently and willingly. | |
| Court membership | |
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| Case opinions | |
| Majority | White, joined by unanimous |
| Laws applied | |
| Federal Kidnapping Act, Fifth Amendment to the United States Constitution | |
Brady v. United States, 397 U.S. 742 (1970), was a United States Supreme Court case in which the Court refused to hold that large sentencing discounts and threats of the death penalty are sufficient evidence of coercion.
Robert Brady was indicted in 1959 for kidnapping and failing to release the hostage without harm which under 18 U.S.C. § 1201(a) imposed a maximum penalty of death if the jury recommended it. When he learned that his co-defendant had confessed to the crime and agreed to testify against him Brady changed his plea from not guilty to guilty. The trial judge twice questioned him on whether the plea was made voluntarily.
Upon his acceptance of his plea the trial judge imposed sentence of fifty years imprisonment, later reduced to thirty.
In 1967 Brady sought post-conviction relief arguing that 18 U.S.C. § 1201(a) was coercive in nature and impermissible under United States v. Jackson which was decided after his conviction. In United States v. Jackson the court ruled that 18 U.S.C. § 1201(a) was unconstitutional because the death sentence could only be imposed by a jury. The court concluded that the statute made death the risk of a jury trial and that this was impermissible. Brady argued that every guilty plea entered under § 1201 was invalid when the fear of death is shown to have been a factor. The District Court for the District of New Mexico denied relief. The District Court concluded that Brady changed his plea to guilty after learning that his codefendant would plead guilty, not due to the threat of death under § 1201. The Appeals Court for the Tenth Circuit agreed with the District Court and denied relief.
Justice White delivered the unanimous opinion of the court. He quotes from United States v. Jackson “the fact that the Federal Kidnapping Act tends to discourage defendants from insisting upon their innocence and demanding a jury trial by jury hardly implies that every defendant who enters a guilty plea to a charge under the Act does so involuntarily.” By ruling that all guilty pleas entered under § 1201 “would rob the criminal process of much of its flexibility.” The court ruled that Brady was not coerced by § 1201. He entered his guilty plea with full knowledge and willingness; it was not the court’s fault that the defendant did not anticipate United States v. Jackson.
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