United States v. Goodwin case brief summary

United States v. Goodwin (Justice Stevens writing for 7-2 majority)

 

Facts: Goodwin is pulled over speeding, attacks a cop, has a suspicious clear plastic bag in his car and is only charged with series of misdemeanors. He flees jurisdiction and is returned three years later. During plea negotiations, Goodwin rejects the misdemeanor offer and asserts right to a jury trial. The case is transferred to another prosecutor who indicts him on felony charges. Goodwin files a motion for acquittal based on vindictive prosecution following his conviction.

 

Stevens Opinion

 

·         This case involves presumptions.

·         Goodwin’s argument is based on case law dealing with post-trial allegations of vindictive prosecution; the presumption is not warranted in the pre-trial setting.

·         The conviction should not be reversed based on a presumption of vindictiveness in the pre-trial stage that might be applicable in post-trial proceedings

·         The prosecutor’s discretion is at its peak in bringing the indictment but decreases only slightly in the period between indictment and trial. 

o   Other evidence may come to light and the prosecutor should have the discretion to adjust the charges accordingly

·         The Court is resisting the expansion of the presumption to preserve prosecutorial discretion.

 

A showing of vindictive prosecution will be easier in the period following a conviction since the prosecution will have presumed to have already taken their best shot. Filing new charges when a defendant exercises a right to appeal will receive scrutiny. In most cases, it will be necessary for the government to show the existence of new evidence or a change in the application of the law to rebut the presumption