Monday, November 4, 2013

Ricketts v. Adamson case brief

Ricketts v. Adamson case brief summary
483 U.S. 1 (1987)

The government sought review of an order of the United States Court of Appeals for the Ninth Circuit, which granted defendant's petition for writ of habeas corpus on grounds that the Double Jeopardy Clause of the United States Constitution barred the prosecution of defendant for first degree murder after defendant breached a plea agreement under which he had pled guilty to a lesser offense.

Defendant entered into a plea agreement with the government and was sentenced and imprisoned pursuant to that plea. Defendant refused to testify as provided by the plea agreement, and after his challenge do the agreement was decided in favor of the government, the government decided to reinstate the initial murder charges. The court of appeals granted defendant's petition for habeas corpus.

  • The Court granted the government's petition for writ of certiorari, and concluded that the appeals court erred when it granted defendant's petition. 
  • The Court held that defendant's breach of the plea agreement between the parties removed the double jeopardy bar to prosecution of defendant on the first-degree murder charges that he faced prior to the plea agreement. 
  • The Court held that the double jeopardy clause did not relieve defendant of the consequences of his voluntary choice to challenge the plea agreement. 
  • Pursuant to the terms of the plea agreement, after defendant's challenge failed, the consequences were that defendant was returned the position he occupied prior to execution of the agreement.


The Court reversed the order of the court of appeals which granted defendant's petition for writ of habeas corpus on double jeopardy grounds.

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

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