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Supreme Court of the United States - 397 U.S. 742
Tags: Criminal law, Capital punishment, Coercion
tl;dr:
The fact that the death penalty is a potential sentence for a particular crime is not sufficient to support a claim that the defendant was coerced into pleading guilty.Video Summary
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The Supreme Court found 18 U.S.C. § 1201(a) valid but declared the death penalty provision unconstitutional as it discouraged the exercise of constitutional rights. The Court clarified that not every guilty plea entered under § 1201(a) should be invalidated if the fear of death was a factor in the plea. The decision did not change the existing test that guilty pleas must be both voluntary and intelligent. In the case of Brady, his guilty plea was found to be voluntary and met both requirements. The State cannot use physical harm or mental coercion to force a defendant to plead guilty, but it can offer leniency in exchange for a guilty plea. The Supreme Court ruled that a guilty plea motivated by the desire for a lesser penalty is not necessarily coerced or involuntary. The admissibility of a confession depends on whether it was given voluntarily, without any compulsion under the Fifth Amendment. The presence and advice of counsel can counteract any possible coercion. Brady's guilty plea was voluntary and not induced by threats or promises. The standard for the voluntariness of guilty pleas requires that the defendant be fully aware of the direct consequences, including any commitments made by the court, prosecutor, or counsel. A guilty plea is only invalid if induced by threats, misrepresentation, or improper promises. Brady's guilty plea was not invalid simply because it was entered to avoid the possibility of a death penalty. However, the State cannot use the death penalty as a tool to coerce a guilty plea.
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