United States v. Armstrong case brief

United States v. Armstrong case brief summary
517 U.S. 456 (1996)

CASE SYNOPSIS

Government appealed from an order of the United States Court of Appeals for the Ninth Circuit affirming the trial court's order dismissing the indictments against respondents for drug and firearms offenses, challenging the court's decision regarding a selective-prosecution claim.

CASE FACTS
Respondents were indicted on charges of conspiring to possess and distribute more than 50 grams of cocaine base, and federal firearms offenses. Respondents filed a motion for discovery or for dismissal of the indictment, alleging that they were selected for federal prosecution because they were African American. The appellate court affirmed the trial court's order of dismissal, holding that a defendant was not required to show that government had failed to prosecute others who were similarly situated.

DISCUSSION

• The Court granted certiorari to determine the appropriate standard for discovery for a selective-prosecution claim. 
• The Court reversed because respondents failed to show that government declined to prosecute similarly situated suspects of other races. 
• The phrase "defendant's defense," as used in Fed. R. Crim. P. 16(a)(1)(C), does not encompass allegations of selective prosecution.

CONCLUSION
The Court reversed and remanded the judgment of the appellate court which affirmed the trial court's order of dismissal.



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