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United States v. Armstrong

(1996)

Supreme Court of the United States - 517 U.S. 456

tl;dr:

In order to prevail on a selective-prosecution claim, a defendant must show that similarly situated individuals of other races were not prosecuted under similar circumstances.

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Facts & HoldingUnited States v. Armstrong case brief facts & holding

Facts:The defendant was arrested and indicted for possession of crack...

Holding:The Court held that, while a defendant cannot get prosecutors'...

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United States v. Armstrong | Case Brief DeepDive
Majority opinion, author: Chief Justice Rehnquist
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The case involves determining if a defendant can receive discovery on a claim that the prosecutor singled them out for prosecution based on their race. The District Court granted the defendant's motion for discovery or dismissal of the indictment, alleging that they were selected for federal prosecution because of their race. The Government filed a motion for reconsideration of the District Court's discovery order and submitted evidence to explain why it had chosen to prosecute the respondents and why their study did not support the inference that the Government was targeting blacks for cocaine prosecution. The District Court denied the Government's motion for reconsideration, and when the Government refused to comply with the court's discovery order, the case was dismissed. However, the court ruled that the defendants did not meet the necessary showing as they failed to prove that the government did not prosecute similarly situated suspects of other races. The Supreme Court granted certiorari to determine the appropriate standard for discovery for a selective-prosecution claim. The court concludes that defendants can examine Government documents material to their defense against the Government's case in chief, but not for the preparation of selective-prosecution claims. A selective-prosecution claim is not a defense to the criminal charge itself, but an independent assertion that the prosecutor has brought the charge for reasons forbidden by the Constitution. The court establishes a "background presumption" that the showing required to obtain discovery should be a significant barrier to the litigation of insubstantial claims. Rule 16(a)(1)(C) refers only to the narrower class of "shield" claims that refute the Government's arguments that the defendant committed the crime charged. Rule 16(a)(2) further establishes that "defense" in subdivision (a)(1)(C) can only refer to defenses in response to the Government's case in chief.

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Opinion (Concurrence), author: Justice Souter
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I agree with the Court's decision, but I only agree with their understanding of a specific rule in criminal procedure for this particular case.

Opinion (Concurrence), author: Justice Ginsburg
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Justice Ginsburg agrees with the Court's conclusion that allegations of selective prosecution do not fall under the "defendant's defense" phrase in Rule 16(a)(1)(C). She clarifies that this ruling is specific to this issue and does not significantly limit the scope of discovery available under Rule 16. Justice Ginsburg points out that the Court did not address whether Rule 16(a)(1)(C) applies to other contexts, such as affirmative defenses not related to the merits. She joins the Court's opinion but emphasizes that it does not preclude the consideration of other unreviewed issues.

Opinion (Concurrence), author: Justice Breyer
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Justice Breyer disagrees with the majority's interpretation of Federal Rule of Criminal Procedure 16, which limits a defendant's discovery rights to documents related to the Government's case in chief. He argues that the Rule allows defendants to inspect and copy physical items that are material to the preparation of their defense, including affirmative defenses, unrelated claims of constitutional right, and foreseeable surrebuttals. Justice Breyer finds no legal support for limiting the Rule's scope in this way, as it creates an arbitrary legal distinction and threatens to create two parallel sets of criminal discovery principles. The majority's argument for the "case in chief" limitation is based on the exemption of Government attorney work product from certain disclosure requirements, but Justice Breyer believes that the work-product exception itself may contain implicit exceptions. He suggests that courts can supplement Rule 16 discovery with discovery based on other legal principles to overcome the Court's problem.

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Dissenting opinion, author: Justice Stevens
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The dissenting opinion in a legal case recognizes the possibility of political or racial bias in criminal proceedings, and the District Judge has the power to investigate discriminatory behavior from the prosecutor or staff. The sentencing disparity between black and white defendants increased during the first 18 months of full guideline implementation, posing a significant threat to the integrity of federal sentencing reform. The District Judge in the Central District of California has ordered the development of facts to determine the standards that govern the choice of forum for similarly situated offenders due to concerns about the fairness of charging practices. Evidence suggests that black defendants charged with distributing crack are disproportionately prosecuted in federal court, while defendants of other races charged with similar offenses are prosecuted in state court. The District Court was justified in finding the evidence significant and requiring an explanation from the government.

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