DeMarco v. United States
Headline: Court sends a drug-trafficking conviction back to the trial court, vacating the appeals ruling and requiring a hearing on whether the Government promised a witness—possibly affecting the defendant’s conviction.
Holding: The Court granted review, vacated the Court of Appeals’ judgment, and ordered a remand to the District Court for an evidentiary hearing on whether the Government promised a witness before trial, which could affect the conviction.
- Requires a district court hearing to resolve whether the Government promised a key witness.
- Could lead to reversal of conviction if a pretrial promise to the witness is proved.
- Limits appeals courts from deciding new factual disputes without a trial-court hearing.
Summary
Background
The case involves a man convicted for trafficking in illegal narcotics and a Government witness who had been indicted along with him. At the trial the witness testified that the Government had made no promises about his case. After the conviction, that witness pleaded guilty to a lesser charge and the U.S. Attorney made statements at sentencing that the defendant read as showing a promise had been made before trial. The defendant raised that issue first in the Court of Appeals instead of asking the trial court to hold a hearing.
Reasoning
The core question was whether any plea deal or promise to the witness was made before the witness testified at the defendant’s trial. The Court said that question was factual and decisive and should not have been resolved for the first time by the Court of Appeals based only on the papers. The Court granted review, vacated the appeals court judgment, and ordered the case sent back to the District Court for an evidentiary hearing to resolve when the plea bargain and any promises were made. The opinion noted that if a pretrial promise were proved, prior cases (Giglio and Napue) would require reversal of the conviction. The Government agreed that initial factfinding belongs to district courts.
Real world impact
The ruling sends the dispute back for a trial-court hearing rather than deciding it on appeal. Criminal defendants who claim a witness was promised leniency before testifying could get a hearing. The decision is procedural and not a final ruling on the conviction; a later District Court finding could lead to reversal if a pretrial promise is shown.
Dissents or concurrances
Justice Rehnquist (joined by the Chief Justice and Justice Powell) dissented, saying this was a purely factual matter of no broad legal importance and that the Court should have denied review because the defendant raised the issue first in the Court of Appeals.
Opinions in this case:
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?