criminal cases Flashcards
Alford v. North Carolina
after being recommended he plea guilty, Alford plead guilty. After hearing presentation of the case, he stated that he was not guilty and only pleads so because he is afraid of a death sentence. Note: judge assured Alford made his decision freely after consulting counsel. Alford still plead guilty, after receiving evidence of Alford’s extensive criminal history he was sentenced to the maximum 30 years.
Answer: No. supreme court held there was no constitutional violation where the defendant concluded based on competent counsel that he should plead guilty, the court saw no difference in someone who admits the crime and who maintains innocence while pleading guilty
Boykin v. Alabama
27-year-old Edward Boykin was indicted for 5 counts of robbery, punishable by death. Pleaded guilty, judge accepts without confirming that Boykin understands his rights, jury sentenced him to death. Triggers appeal to supreme court, affirmed sentence, 3 justices dissented as trial failed to show that Boykin’s plea was voluntary.
Issue: did the trail court create a reversable error when it failed to confirm that the petitioner’s plea was voluntary and that he was aware of his rights?
Court decision: yes.
Santobello v. NY
santobello convicted on 2 felony counts, plea not guilty. Prosecutor offers plea deal for lighter sentence recommendation. Santobello accepts. Several months later he is not sentenced, by the time he is sentenced the original prosecutor and defense council have been changed and are unaware of plea offer. New prosecutor recommends max 1 year sentence, court agrees, santobello appeals and court affirms max sentence. Eventually court allows santobello to withdraw his plea.
Precedent set? Plea deals made have to be honored.
Borkenkircher v. Hayes
Paul Lewis Hayes (defendant) was indicted on a charge of uttering a forged instrument in the amount of $88.30, punishable by up to 10 years imprisonment. Hayes offered 5 year sentence if he plead guilty. Hayes chose not to plead guilty and the prosecutor obtained an indictment charging him under the state’s Habitual Criminal Act. Hayes was subsequently found guilty of the uttering offense and sentenced to life imprisonment.
The Kentucky Court of Appeals affirmed the sentence. Hayes then filed a petition for a federal writ of habeas corpus. The court of appeals held that the prosecutor’s conduct during the plea negotiations had violated the principles which “protected defendants from the vindictive exercise of a prosecutor’s discretion,” and ordered Hayes’ sentence to be reduced to a lawful sentence imposed only for the uttering crime. The United States Supreme Court granted certiorari to review.
U.S. v. Salerno
Anthony Salerno (defendant) and another man were arrested after being charged on a 29-count indictment alleging violations of the Racketeer Influenced and Corrupt Organizations Act (RICO). At Salerno’s arraignment, the government moved to have him detained pursuant to the Bail Reform Act. At the hearing, the government proffered evidence that Salerno was the “boss” of a powerful crime family who had furthered the crime family’s illegal enterprises through violent means and had personally participated in two murder conspiracies. The district court granted the government’s detention motion, concluding that the government had met its burden of showing that no conditions of Salerno’s release would ensure the safety of others or the community. The court of appeals reversed, holding that the Bail Reform Act was unconstitutional on its face as a violation of due process. The United States Supreme Court granted certiorari.
Blackledge v. Allison
charged in North Carolina state court with breaking and entering, attempted safe robbery, and possession of burglary tools. Allison pleaded guilty to a single count of attempted safe robbery, which exposed him to a sentencing range of 10 years to life in prison. At a hearing, the judge asked standard questions from a form; Allison answered the questions and signed the form. In relevant part, the form indicated that Allison understood the possible sentencing range for his plea and that no one had promised Allison anything to induce his plea. The trial court accepted Allison’s plea, and three days later, the court sentenced Allison to 17 to 21 years in prison. No transcripts were available from Allison’s plea colloquy or sentencing hearing. After Allison exhausted his state collateral appeals, he filed a pro se habeas corpus petition in federal district court, alleging that his guilty plea had been induced by an unkept promise of a 10-year sentence.
Decision: The United States Court of Appeals for the Fourth Circuit reversed and remanded the case for an evidentiary hearing, finding that Allison had sufficiently alleged a claim that, if proven, would entitle him to habeas relief and that the government had produced no evidence that conclusively proved that Allison’s claims were false. The United States Supreme Court granted certiorari.
