Kercheval v. United States
Headline: Court bars prosecutors from using a defendant’s withdrawn guilty plea as evidence at a later trial, protecting people who withdraw pleas from having that prior plea used to secure a conviction.
Holding:
- Prevents use of withdrawn guilty pleas as evidence at later trials.
- Protects defendants who successfully withdraw guilty pleas from that plea’s evidentiary weight.
- Requires courts to honor orders vacating guilty pleas.
Summary
Background
A man indicted in federal court in western Arkansas for using the mails to defraud pleaded guilty and was sentenced to three years in prison. He later said he pleaded guilty only because a prosecuting attorney promised to recommend a much lighter sentence and the court then allowed him to withdraw that guilty plea and enter a not-guilty plea. At the subsequent trial the government introduced a certified copy of the withdrawn guilty plea as evidence and the jury convicted him again.
Reasoning
The central question was whether a guilty plea that a court has later set aside can be used as evidence at the trial on the substituted not-guilty plea. The Court explained that a guilty plea functions as a conviction like a jury verdict, and when a court vacates that plea it is held for naught and ceases to be evidence. Allowing the withdrawn plea to be used would conflict with the court’s own order and place the defendant in an unfair dilemma, so admission of the withdrawn plea was improper.
Real world impact
This ruling prevents prosecutors from relying on a defendant’s withdrawn guilty plea as proof of guilt at a later trial. Courts must honor their orders that vacate pleas and defendants who obtain withdrawal of a plea get the protection intended by that order. The Supreme Court reversed the conviction below.
Dissents or concurrances
One Justice (Stone) agreed with the result of reversing the judgment.
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