McCarthy v. United States

Background

A 65-year-old man was indicted on three counts of tax evasion. At a pretrial hearing his lawyer said he had advised the man about pleading guilty, and the man pleaded guilty to one count while the government agreed to dismiss the other two. The judge told him about the penalties and accepted the plea without personally questioning whether he understood the nature of the charge. At sentencing the man and his lawyer said his tax problems grew from neglect and serious health and drinking issues, but the judge sentenced him to one year in prison and a fine. He appealed, arguing the judge had not followed Rule 11 of the Federal Rules of Criminal Procedure.

Reasoning

The Court framed the central question simply: what procedure must a judge follow before accepting a guilty plea, and what happens if the judge does not follow it? The Court explained that the 1966 amendment to Rule 11 requires the judge to address the defendant personally to make sure the plea is voluntary and that the defendant understands the charge. The Rule also aims to create a clear record to reduce needless post-conviction challenges. Because the judge here did not personally probe the defendant’s understanding, the Court found that Rule 11 was not followed and that this noncompliance prejudiced the defendant.

Real world impact

The Court reversed the appeals court and said a defendant whose plea was accepted in violation of Rule 11 is entitled to plead again. The decision requires federal judges to take a few minutes to question defendants directly and to ensure a factual basis is on the record. It applies across the federal courts and is aimed at improving the accuracy and finality of guilty-plea convictions.

Dissents or concurrances

Justice Black wrote a short concurrence agreeing with reversal because the judge failed to address the defendant personally as Rule 11 requires, although he expressed some doubt about the result.