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United States v. Armstrong

517 U.S. 456 (1996)

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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The case of "United States v. Armstrong et al." involved defendants who claimed they were targeted for prosecution based on their race. However, the Court ruled that they did not provide enough evidence to support their claim. The charges against the defendants were for conspiring to possess and distribute crack cocaine and federal firearms offenses. The Supreme Court granted certiorari to determine the appropriate standard for discovery in a selective-prosecution claim. The court rejected the argument that the defendant's defense in Rule 16 includes any claim challenging the prosecution's conduct of the case. Therefore, the government is not required to provide documents related to its prosecution strategy for cocaine cases as they are not material to the defendant's response to the Government's case in chief. The lower court did not err in granting the motion for discovery or dismissal of the indictment. To prove a violation of equal protection, a defendant must provide clear evidence to the contrary. Courts are hesitant to examine prosecutorial decisions due to concerns about delaying criminal proceedings, chilling law enforcement, and undermining prosecutorial effectiveness. To make a selective-prosecution claim, a defendant must show that the federal prosecutorial policy had a discriminatory effect and was motivated by a discriminatory purpose. The requirement for a showing of failure to prosecute similarly situated individuals applies when a federal court challenges the power of the Executive Branch of the Federal Government to prosecute. Batson v. Kentucky established standards for assessing a prima facie case of discriminatory selection of the venire in a criminal trial.

To prove selective prosecution, defendants must provide evidence of discriminatory effect and intent, and evidence of failure to prosecute others is required to establish a colorable basis for discriminatory effect. The Court of Appeals erred in holding otherwise. Justice Breyer disagrees with the Court's interpretation of Rule 16, arguing that the rule's language suggests a broader scope of discovery than the Court's interpretation. The District Judge has the inherent power to investigate if a prosecutor has singled out defendants based on race, but this power is not derived from Rule 16. Evidence suggests that black defendants charged with crack distribution are prosecuted in federal court, while defendants of other races charged with similar offenses are prosecuted in state court. The lower court did not err in considering affidavits submitted by the respondents, which contained information based on personal observations or an attorney's practice that can tend to show selective prosecution. The District Court was entitled to find the evidence significant and require an explanation from the government.

The Sentencing Commission recognizes that discretionary decisions in cocaine cases can lead to arbitrary enforcement and discriminatory claims. The District Judge ordered discovery to explain the racial pattern of cases before her court, which is supported by the dissenting opinion. The majority's conclusion that the District Judge exceeded her power or abused her discretion is not accepted.

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IRACIssue, Rule, Analysis, Conclusion

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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

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