United States v. Davila
January 4, 2013
Case #: 12-167
Court Below: Court of Appeals for the Eleventh Circuit, 664 F.3d 1355 (2011)
Full Text Opinion: http://www.ca11.uscourts.gov/opinions/ops/201015310.pdf
Criminal Procedure: Whether the court of appeals erred in finding that a criminal defendant's guilty plea should be vacated when a judicial participation occurs in violation of Federal Rule of Criminal Procedure 11(c)(1), irrespective of individual prejudice to the defendant.
After Respondent asked the federal magistrate judge to discharge his court-appointed attorney because the only defense strategy he would discuss was pleading guilty, the magistrate judge responded by telling Respondent “there may not be viable defenses to these charges” and informed him that if he accepted responsibility he could get a three-level reduction in his sentence. Respondent pled guilty and was subsequently sentenced to 115 months incarceration.
The Court of Appeals for the Eleventh Circuit held that a defendant need not show individual prejudice if the magistrate had any involvement with negotiations in violation of Fed. R. Crim. P. 11(c)(1), and vacated Respondent’s conviction.
On appeal, the Government argues that a guilty plea should only be overturned if the communication actually prejudiced the defendant.