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United States v. Davila

Summarized by: 

Date Filed: June 13, 2013
Case #: 12-167
Ginsburg, J., delivered the opinion of the Court, in which Roberts, C. J., and Kennedy, Breyer, Alito, Sotomayor, and Kagan, JJ., joined. Scalia, J., filed an opinion concurring in part and concurring in the judgment, in which Thomas, J., joined.
Full Text Opinion: http://www.supremecourt.gov/opinions/12pdf/12-167_d1oe.pdf

Criminal Procedure: A plea cannot be vacated for an error under Federal Rule of Criminal Procedure 11(h) unless the the error results in prejudice to the defendant's decision to plead guilty.

Respondent was indicted on multiple tax fraud charges. At an in camera hearing, a U.S. Magistrate Judge told Respondent that his best option was to plead guilty to the charges so that he would be eligible to receive a reduced sentence. Three months later, Respondent pleaded guilty. 

On appeal, the government conceded that the Magistrate Judges in camera comments violated Federal Rule of Criminal Procedure 11(c)(1), which prohibits judges from participating in plea discussions. The Court of Appeals for the Eleventh Circuit vacated Respondent’s guilty plea. Applying circuit precedent, the court concluded that a violation of Rule 11(c)(1) required automatic vacatur of the guilty plea, and thus the court did not determine whether the error was prejudicial.

The Supreme Court held that a plea could not be vacated for a violation of Rule 11(c)(1) unless the record showed prejudice to a defendant’s decision to plead guilty. The Court observed that under Rule 11(h), a violation of Rule 11 “is harmless error if it does not affect substantial rights,” and the Court concluded that Rule 11(h)’s “harmless error” analysis was controlling. Noting that the court below had not considered whether Respondent had actually suffered prejudice, the Court vacated the judgment of the Court of Appeals, and remanded the case.