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Law School Case Brief

Ricketts v. Adamson - 483 U.S. 1, 107 S. Ct. 2680 (1987)


A defendant, by deliberately choosing to seek termination of the proceedings against him on a basis unrelated to factual guilt or innocence of the offense of which he was accused, suffers no injury cognizable under the Double Jeopardy Clause. The Double Jeopardy Clause does not relieve a defendant from the consequences of his voluntary choice.


After his trial on charges of first degree murder had commenced, defendant John Harvey Adamson entered into a plea agreement with the State of Arizona, under which Adamson pled guilty to second degree murder, sentenced, and imprisoned pursuant to that plea. The agreement added that should Adamson refuse to testify or at any time testify untruthfully, then the entire agreement was "null and void" and the original charge would automatically be reinstated. Although Adamson testified at the trial of two accomplices, who were convicted, Adamson refused to testify at the retrials of the other two defendants after their convictions were reversed on appeal. The State of Arizona reinstated the original first-degree murder charge. Adamson then sought federal habeas corpus relief, but the United States District Court for the District of Arizona dismissed Adamson’s petition. A panel of the United States Court of Appeals for the Ninth Circuit initially affirmed the dismissal, but an en banc decision of the Court of Appeals eventually directed the issuance of a writ of habeas corpus, on the ground that the state had violated Adamson's rights under the double jeopardy clause of the Fifth Amendment to the United States Constitution. The United States Supreme Court granted the State of Arizona's petition for certiorari review.


Did the prosecution of defendant for first-degree murder, after he challenged a plea agreement entered into with the state, violate the defendant’s rights under the double jeopardy clause of the Fifth Amendment to the U.S. Constitution?




The United States Supreme Court held that defendant's breach of the plea agreement between the parties removed the double jeopardy bar to prosecution of defendant on the first-degree murder charges that he faced prior to the plea agreement. The Court held that the double jeopardy clause did not relieve defendant of the consequences of his voluntary choice to challenge the plea agreement. Pursuant to the terms of the plea agreement, after defendant's challenge failed, the consequences were that defendant was returned the position he occupied prior to execution of the agreement.

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