Tuesday, December 24, 2013

United States v. Powell case brief

United States v. Powell case brief summary
469 U.S. 57 (1984)


CASE SYNOPSIS
Respondent inmate was convicted of three counts of the compound offenses of using the telephone in committing and in causing and facilitating certain felonies in violation of 21 U.S.C.S. § 843(b) and was acquitted on a fourth count of the same charge as well as the underlying narcotics charges. The United States Court of Appeals for the Ninth Circuit reversed the verdicts because they were inconsistent. The government sought a writ of certiorari.

CASE FACTS
The inmate was acquitted of various narcotics charges but convicted of the compound offenses of using the telephone in committing and in causing and facilitating certain felonies under § 843(b). The appellate court reversed holding that there was an exception to the Dunn rule when a defendant was convicted under§ 843(b).

DISCUSSION

  • On appeal, the Court rejected, as imprudent and unworkable, a rule that would allow criminal defendants to challenge inconsistent verdicts on the ground that in their case the verdict was not the product of lenity but of some error worked against them. 
  • The Court found that a criminal defendant was already afforded protection against jury irrationality or error by the independent review of the sufficiency of the evidence undertaken by the trial and appellate courts. 
  • The Court determined that there was no reason to vacate the inmate's conviction merely because the verdicts could not rationally be reconciled. 
  • The Court held that the inmate was given the benefit of her acquittal on the counts on which she was acquitted and that is was neither irrational nor illogical to require her to accept the burden of conviction on the counts on which the jury convicted.
CONCLUSION
The Court granted the writ of certiorari and reversed the judgment of the appellate court reversing inmate's convictions on the compound offenses of using the telephone in committing and in causing and facilitating certain felonies because consistency in the verdict was not necessary.


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