Sunday, November 17, 2013

United States v. Bailey case brief

United States v. Bailey case brief summary
444 U.S. 394 (1980)

Petitioner United States sought review of judgments from the United States Court of Appeals for the District of Columbia reversing respondents' convictions for escaping from prison and violating 18 U.S.C.S. § 751(a) on grounds that the trial court erred by disallowing consideration of evidence of duress and necessity.

Respondents, federal prisoners, escaped from jail and were eventually recaptured and charged with violating 18 U.S.C.S. § 751(a), governing escape from federal custody. At their trials, respondents adduced evidence as to various conditions and events at the jail where they were incarcerated, claiming that such conditions necessitated their escape. The juries were instructed to disregard the evidence, and respondents were convicted.

The appellate court reversed the convictions, holding that the trial court had improperly precluded jury consideration of respondents' tendered evidence. The court granted certiorari and reversed.


  • According to the court, the trial court was correct in demanding that respondents show some evidence that they attempted to surrender or engaged in equivalent conduct once they had freed themselves from the conditions they described. 
  • When respondents failed to provide such evidence, the trial court correctly ruled that respondents had failed as a matter of law to present evidence sufficient to support the defense of necessity or duress because they had not turned themselves in after they had escaped the allegedly coercive conditions.

The judgments of the court of appeals were reversed as a result of the court's finding that respondents failed to introduce evidence sufficient to submit their defenses of duress and necessity to the juries, and the juries below were thus properly instructed.

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