Tuesday, December 24, 2013

United States v. Young case brief

United States v. Young case brief summary
470 U.S. 1 (1985)

Respondent was convicted of various federal offenses after a trial in which both defense counsel and the prosecutor made inflammatory remarks during closing argument. The United States Court of Appeals for the Tenth Circuit reversed the conviction on the basis of plain error and the government sought a writ of certiorari.

During the closing argument phase of respondent's trial, defense counsel made comments to the effect that not even the prosecutor believed in respondent's guilt. The prosecutor then argued that he did believe respondent to be guilty of the crimes charged. Defense counsel failed to object.


  • In overturning the appellate court's judgment, the Court held that the prosecutor's remarks were clearly improper and unethical. 
  • However, the Court held that the prosecutor's response to defense counsel's misconduct did not rise to the level of plain error such that a reversal was warranted. 
  • The Court noted that the plain error doctrine of Fed. R. Crim. P. 52(b) was to be used sparingly and only in the event of a particularly egregious error in which a miscarriage of justice would otherwise result. 
  • An examination of the record as a whole revealed that this was not an error that entitled respondent to a reversal of his conviction.
The court reversed the appellate court's judgment, which had reversed respondent's conviction and had ordered a new trial.

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