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Law School Case Brief

Brady v. United States - 397 U.S. 742, 90 S. Ct. 1463 (1970)

Rule:

Waivers of constitutional rights not only must be voluntary but must be knowing, intelligent acts done with sufficient awareness of the relevant circumstances and likely consequences.

Facts:

Defendant was charged with kidnapping in violation of 18 U.S.C.S. § 1201(a). Since the victim had not been liberated unharmed, defendant faced a maximum penalty of death under the statute if a jury should so recommend. Defendant pled guilty after learning that his co-defendant would plead guilty and be available to testify against him. Defendant subsequently sought post-conviction relief pursuant to 28 U.S.C.S. § 2255 upon the claim that his plea was not voluntarily given because 18 U.S.C.S. § 1201(a) operated to coerce his plea. Defendant's argument was based on a later decision, which found the death penalty provision of § 1201(a) to be unconstitutional, because the inevitable effect of that specific provision was said to needlessly encourage pleas of guilty and waivers of jury trial. However, that decision did not rule that all pleas of guilty encouraged by the fear of a possible death sentence were involuntary or invalid. On appeal, the Court of Appeals affirmed the denial of defendant's requested relief under 28 U.S.C.S. § 2255 upon the finding that defendant's plea had been voluntarily and knowingly made. The case was appealed to the United States Supreme Court.

Issue:

Was the denial of post-conviction relief to a defendant who had pled guilty to avoid the death penalty proper?

Answer:

Yes.

Conclusion:

Despite the fact that defendant's plea of guilty may have been motivated in part by a desire to avoid a possible death penalty, the conviction was confirmed because the trial court had been convinced both that the plea had been voluntarily and intelligently made and the court had no reason to doubt that his solemn admission of guilt had been truthful. The Supreme Court held that, after considering all the relevant circumstances surrounding defendant's plea, there was nothing in the record that suggested that his admissions were anything but the truth, and affirmed the acceptance of the plea.

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