Law School Case Brief
United States v. Mezzanatto - 513 U.S. 196, 115 S. Ct. 797 (1995)
A party may waive any provision, either of a contract or of a statute, intended for his benefit. The most basic rights of criminal defendants are subject to waiver. A criminal defendant may knowingly and voluntarily waive many of the most fundamental protections afforded by the Constitution. Likewise, absent some affirmative indication of Congress' intent to preclude waiver, statutory provisions are subject to waiver by voluntary agreement of the parties.
In a federal drug prosecution, Mezzanatto and his attorney asked for a pretrial meeting with the prosecutor to discuss the possibility of cooperating with the Federal Government. The prosecutor indicated that as a condition to proceeding with such discussions, Mezzanatto would have to agree that any statements that he made during the meeting could be used to impeach any contradictory testimony that he might give at trial. Mezzanatto conferred with his attorney and agreed to proceed under the prosecutor's terms, but the meeting was terminated on the ground that Mezzanatto had failed to provide completely truthful information. Subsequently, Mezzanatto was tried in Federal District Court on a federal drug charge and testified in his own defense. Over defense counsel's objection, the prosecutor cross-examined the accused about allegedly inconsistent statements that Mezzanatto had made during the pretrial meeting. Mezzanatto was found guilty and was sentenced to imprisonment. The United States Court of Appeals for the Ninth Circuit reversed and remanded the case, expressing the view that plea-statement rules provide that statements made in the course of plea discussions between an accused and a prosecutor are generally inadmissible against the accused--plea negotiation statements are not admissible to impeach an accused; the protection of the plea-statement rules may not be waived by an accused; and reversal was necessary because the District Court's error in admitting the plea statements was not harmless.
Was the evidence properly admitted because Mezzanatto had voluntarily entered into the agreement to waive the exclusionary provisions of the plea-statement rules?
The Court ruled that, absent some affirmative indication that the agreement was entered into unknowingly or involuntarily, an agreement to waive the exclusionary provisions of the plea-statement rules was valid and enforceable. The Court found that such a rule would not bring plea bargaining to a halt, but might well have the opposite effect. Because Mezzanatto had voluntarily entered into the agreement, the evidence was properly admitted.
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