Saturday, November 2, 2013

Brady v. United States case brief

Brady v. United States case brief summary
397 U.S. 742 (1970)

Defendant, who was convicted of kidnapping in violation of 18 U.S.C.S. § 1201(a), sought review of the judgment of the United States Court of Appeals for the Tenth Circuit, which affirmed the denial of defendant's requested relief under 28 U.S.C.S. § 2255 upon the finding that defendant's plea had been voluntarily and knowingly made.


  • Defendant was charged with kidnapping in violation of 18 U.S.C.S. § 1201(a). 
  • Since the victim had not been liberated unharmed, defendant faced a maximum penalty of death under the statute if a jury should so recommend. defendant pled guilty after learning that his codefendant would plead guilty and be available to testify against him. defendant subsequently sought relief pursuant to 28 U.S.C.S. § 2255 upon the claim that his plea was not voluntarily given because 18 U.S.C.S. § 1201(a) operated to coerce his plea.
  • Defendant's argument was based on a later decision, which found the death penalty provision of § 1201(a) to be unconstitutional, and because the inevitable effect of that provision was said to needlessly encourage pleas of guilty and waivers of jury trial. 
  • However, that decision did not rule that all pleas of guilty encouraged by the fear of a possible death sentence were involuntary or invalid. 
  • The court considered all the relevant circumstances surrounding defendant's plea, determined that it was voluntarily and intelligently made, found that nothing in the record suggested that his admissions were anything but the truth, and affirmed the acceptance of the plea.


The judgment was affirmed despite the fact that defendant's plea of guilty may have been motivated in part by a desire to avoid a possible death penalty because the court was convinced that the plea had been voluntarily and intelligently made and because the court had no reason to doubt that his solemn admission of guilt had been truthful.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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