United States v. Mezzanatto case brief summary
513 U.S. 196 (1995)
CASE FACTS
Respondent entered into plea negotiations with the prosecution, during which he agreed to waive the provisions of Fed. R. Evid. 410 and Fed. R. Crim. P. 11(e)(6), which provided that statements made in the course of plea discussions between a criminal defendant and a prosecutor were inadmissible against the defendant. Discussions broke down between the parties and respondent was convicted at trial for possessing methamphetamine with intent to distribute. At trial, the prosecution impeached respondent with statements he had made during plea discussions. The court of appeals determined that respondent's conviction could not stand because the protections conferred by the plea-statement rules could not be waived.
DISCUSSION
CONCLUSION
The court reversed the ruling of the court of appeals, finding that respondent did properly waive his rights to have the statements he made in plea negotiations excluded from his trial.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
513 U.S. 196 (1995)
CASE SYNOPSIS
The government challenged an order from
the United States Court of Appeals for the Ninth Circuit that
reversed a district court's conviction of respondent after finding
that the protections conferred by Fed. R. Evid. 410 and Fed.
R. Crim. P. 11(e)(6), which provided that statements made in the
course of plea discussions between a criminal defendant and a
prosecutor were inadmissible against a defendant, could not be
waived.CASE FACTS
Respondent entered into plea negotiations with the prosecution, during which he agreed to waive the provisions of Fed. R. Evid. 410 and Fed. R. Crim. P. 11(e)(6), which provided that statements made in the course of plea discussions between a criminal defendant and a prosecutor were inadmissible against the defendant. Discussions broke down between the parties and respondent was convicted at trial for possessing methamphetamine with intent to distribute. At trial, the prosecution impeached respondent with statements he had made during plea discussions. The court of appeals determined that respondent's conviction could not stand because the protections conferred by the plea-statement rules could not be waived.
DISCUSSION
- On petition to the Court, however, the Court ruled that, absent some affirmative indication that the agreement was entered into unknowingly or involuntarily, an agreement to waive the exclusionary provisions of the plea-statement rules was valid and enforceable.
- The Court found that such a rule would not bring plea bargaining to a halt, but might well have the opposite effect.
- Because respondent had voluntarily entered into the agreement, the evidence was properly admitted.
CONCLUSION
The court reversed the ruling of the court of appeals, finding that respondent did properly waive his rights to have the statements he made in plea negotiations excluded from his trial.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
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