Home › Case briefs › Criminal Procedure

Brady v. United States

Supreme Court of the United States · 1970 · Criminal Procedure

guilty pleavoluntarinessplea bargainingwaiver of rightsguilty pleavoluntary and intelligent pleaplea bargainingdeath penalty incentive

Facts

Brady was indicted in 1959 under 18 U.S.C. § 1201(a) for kidnapping a victim who was not liberated unharmed, exposing him to a possible death sentence if a jury so recommended. Represented by competent counsel, he initially pleaded not guilty, but changed his plea to guilty after learning that his codefendant, who had confessed, would plead guilty and be available to testify against him. The trial judge questioned Brady twice about whether his plea was voluntary before accepting it, and Brady later received a prison sentence that was reduced from 50 years to 30. In his § 2255 motion, Brady claimed the plea was involuntary because the statute coerced him, counsel pressured him, and promises were made about sentence reduction and clemency, but the lower courts found no impermissible pressure or promises and found the plea voluntary and knowing.

Issue

Whether Brady's guilty plea was invalid because it was influenced by the possibility of a death sentence under 18 U.S.C. § 1201(a), later held unconstitutional in part in United States v. Jackson. More broadly, the question was whether a plea entered to avoid the risk of a harsher penalty is involuntary or unintelligent under the Fifth Amendment.

Rule

A guilty plea is constitutionally valid if it is voluntary and intelligent. A plea entered by a defendant fully aware of the direct consequences, including the actual value of any commitments made by the court, prosecutor, or defense counsel, must stand unless induced by threats, misrepresentation, unfulfilled or unfulfillable promises, or promises that are improper by their nature; a plea is not invalid merely because it was entered to avoid the possibility of a higher penalty, even a death sentence, or because later judicial decisions change the understood legal consequences.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Daniel Ruiz was charged with armed robbery under a statute authorizing 5 to 25 years after trial. After reviewing surveillance footage and two eyewitness statements with his lawyer, he pleaded guilty in exchange for the prosecutor's recommendation of 8 years. Daniel later moves to withdraw the plea, arguing it was involuntary because he pleaded only to avoid the risk of a much longer sentence.

How should the court rule?

Explanation. A guilty plea is valid if it is voluntary and intelligent. Under the majority rule, the fact that a defendant pleads guilty to avoid a harsher lawful sentence does not by itself make the plea compelled. The state may encourage pleas through the prospect of leniency or avoidance of a greater authorized penalty, so long as the plea is not induced by threats, misrepresentation, or improper promises and the defendant can rationally weigh the alternatives with counsel.