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Law School Case Brief

United States v. Kaczynski - 239 F.3d 1108 (9th Cir. 2001)


To determine voluntariness, courts examine the totality of the circumstances. A plea is voluntary if it represents a voluntary and intelligent choice among the alternative courses of action open to the defendant. A plea of guilty entered by one fully aware of the direct consequences must stand unless induced by threats (or promises to discontinue improper harassment), misrepresentation (including unfulfilled or unfulfillable promises), or perhaps by promises that are by their nature improper as having no proper relationship to the prosecutor's business (e.g. bribes). In sum, a guilty plea is void if it was induced by promises or threats which deprive it of the character of a voluntary act.


Defendant moved to vacate his conviction alleging that his guilty plea to indictments returned against him as the "Unabomber" was involuntary. The district court found that defendant's self-representation request was untimely and not in good faith, that counsel could control the presentation of evidence, and that the plea was voluntary. Accordingly, the district court denied the motion to vacate, with calling for a response or holding a hearing. Defendant appealed.


Is the guilty plea of the defendant involuntary?




The district court's denial of defendant's habeas petition was affirmed where his guilty plea was not rendered involuntary on account of the wrongful denial of his self-representation request or because of anticipation of evidence about his mental condition. While wrongly denying a defendant’s request to represent himself forces him to choose between pleading guilty and submitting to a trial would be unconstitutional, this does not apply in this case because his request for self-representation was validly denied.

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