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United States v. Mechanik - 475 U.S. 66, 106 S. Ct. 938 (1986)


The petit jury's subsequent guilty verdict means not only that there is probable cause to believe that the defendants are guilty as charged, but also that they are in fact guilty as charged beyond a reasonable doubt. Measured by the petit jury's verdict, then, any error in the grand jury proceeding connected with the charging decision was harmless beyond a reasonable doubt. 


After a federal grand jury indicted Mechanik and Lill for drug-related offenses and conspiracy, the prosecutor successfully sought a superseding indictment expanding the conspiracy charge, presenting in support of that indictment the testimony of two law enforcement agents who were sworn together and testified in tandem before the grand jury. Mechanik and Lill did not learn about this joint testimony until their trial before the United States District Court for the Southern District of West Virginia had already begun, although they had diligently searched for error and the prosecution apparently had not deliberately concealed the event. They then moved to dismiss the indictment, contending that the simultaneous presence of the two agents had violated Rule 6(d) of the Federal Rules of Criminal Procedure; but the District Court took the motion under advisement until after the petit jury had returned a guilty verdict, and then denied it, holding that Rule 6(d) had been violated but that the error was harmless as to all counts of the indictment. A panel of the United States Court of Appeals for the Fourth Circuit reversed and remanded with regard to the conspiracy counts and directed that that portion of the indictment be dismissed, holding that the Rule 6(d) violation invalidated the superseding indictment, but affirmed as to the other counts which had simply been incorporated from the original indictment (735 F2d 136). This decision was upheld by the Court of Appeals after rehearing en banc (756 F2d 994).


Did the petit jury's verdict render harmless any conceivable error in the charging decision that might have flowed from the violation?




The Court determined that the petit jury's verdict of guilty beyond a reasonable doubt demonstrated a fortiori that there was probable cause to charge defendants with the offenses for which they were convicted. Concluding that the petit jury's verdict rendered harmless any conceivable error in the charging decision that might have flowed from the violation, the Court reversed the appeals court judgment to the extent that it set aside the conspiracy convictions and dismissed the indictment.

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