13 June 2013

Law in Plain English: United States v. Davila

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

United States v. Davila

A judge told Davila that he should accept responsibility for his crimes (filing over 130 fraudulent tax returns) and that pleading guilty might be the best advice an attorney could provide him. However, the Federal Rules of Criminal Procedure (specifically, rule 11(c)) state that judges must not participate in plea agreements between an attorney for the government and the defendant's attorney. Davila pled guilty and was sentenced. The Eleventh Circuit reversed, finding that any participation by the judge requires automatic reversal. The question before the Court was whether the court of appeals erred in holding that any degree of judicial participation in plea negotiations, in violation of the Federal Rule of Criminal Procedure, automatically requires vacatur of a defendant’s guilty plea, irrespective of whether the error prejudiced the defendant. In a 9-0 decision, the Supreme Court ruled that under rule 11(h), vacatur of the plea is not in order if the record shows no prejudice to Davila’s decision to plead guilty. As a result, the Eleventh Circuit's automatic reversal rule is overturned. The practical impact of this decision is that when such a rule violation occurs, courts will have to examine the record to show that the violation actually resulted in prejudice.
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