Menna v. New York

Background

A man who had been promised immunity refused to answer questions before a grand jury investigating a murder conspiracy and later refused a court order to return. He was held in contempt under New York law and served a flat 30-day jail term. Months later he was indicted for the same refusal. He pleaded guilty after unsuccessfully arguing the new indictment violated the Constitution’s protection against double punishment.

Reasoning

The Supreme Court addressed whether a guilty plea entered with counsel automatically prevents a person from raising a constitutional bar to prosecution. The Court said no: if the Constitution forbids the State from bringing a charge, a conviction on that charge must be set aside even when the defendant pleaded guilty with counsel. The Court remanded the case to the New York Court of Appeals to decide the double jeopardy claim on its merits, explaining that pleas remove factual-guilt disputes but do not waive constitutional defects that make a prosecution itself unlawful.

Real world impact

This ruling lets defendants press claims that the Constitution forbids certain prosecutions even after they have entered counseled guilty pleas. State courts must decide double jeopardy claims on their merits rather than treating them as automatically waived. Because New York treated the earlier contempt as a criminal conviction for the same conduct, some convictions could be overturned if the court finds the double jeopardy bar applies.

Dissents or concurrances

Justice Brennan agreed with the outcome but would have reversed outright, while the Chief Justice and Justice Rehnquist would have called for full argument.