Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

defendantdiscoveryappealpleamotionplea bargainrespondentgrand jury
defendantdiscoveryappealpleamotionplea bargainrespondentgrand jury

Related Cases

Gerezano-Rosales; U.S. v.
View Case »
Salmon, Matter of
View Case »
Yaguil v. Lee
View Case »
Garberding v. Immigration and Naturalization Service
View Case »
Bakuaya v. Mukasey
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Bass; U.S. v.

Facts

A federal grand jury sitting in the Eastern District of Michigan returned a second superseding indictment charging respondent with, inter alia, the intentional fire-arm killings of two individuals. The United States filed a notice of intent to seek the death penalty. Respondent, who is black, alleged that the Government had determined to seek the death penalty against him because of his race. He moved to dismiss the death penalty notice and, in the alternative, for discovery of information relating to the Government's capital charging practices. The District Court granted the motion for discovery, and after the Government informed the court that it would not comply with the discovery order, the court dismissed the death penalty notice. A divided panel of the United States Court of Appeals for the Sixth Circuit affirmed the District Court's discovery order.

A federal grand jury sitting in the Eastern District of Michigan returned a second superseding indictment charging respondent with, inter alia, the intentional fire-arm killings of two individuals. The United States filed a notice of intent to seek the death penalty. Respondent, who is black, alleged that the Government had determined to seek the death penalty against him because of his race. He moved to dismiss the death penalty notice and, in the alternative, for discovery of information relating to the Government's capital charging practices. The District Court granted the motion for discovery, and after the Government informed the court that it would not comply with the discovery order, the court dismissed the death penalty notice. A divided panel of the United States Court of Appeals for the Sixth Circuit affirmed the District Court's discovery order.

Issue

Whether the respondent was entitled to discovery on a claim of selective prosecution based on allegations of discriminatory effect and intent.

Whether the respondent was entitled to discovery on a claim of selective prosecution based on allegations of discriminatory effect and intent.

Rule

Under Armstrong, a defendant who seeks discovery on a claim of selective prosecution must show some evidence of both discriminatory effect and discriminatory intent.

Under Armstrong, a defendant who seeks discovery on a claim of selective prosecution must show some evidence of both discriminatory effect and discriminatory intent.

Analysis

The court applied the rule from Armstrong, stating that the defendant must make a 'credible showing' that 'similarly situated individuals of a different race were not prosecuted.' The Sixth Circuit concluded that the respondent had made such a showing based on nationwide statistics. However, the Supreme Court rejected this evidence, explaining that raw statistics regarding overall charges do not address the treatment of similarly situated defendants, and the plea bargain statistics were irrelevant since the respondent had been offered a plea bargain but declined it.

The court applied the rule from Armstrong, stating that the defendant must make a 'credible showing' that 'similarly situated individuals of a different race were not prosecuted.' The Sixth Circuit concluded that the respondent had made such a showing based on nationwide statistics. However, the Supreme Court rejected this evidence, explaining that raw statistics regarding overall charges do not address the treatment of similarly situated defendants, and the plea bargain statistics were irrelevant since the respondent had been offered a plea bargain but declined it.

Conclusion

The Court reversed the judgment of the circuit court, stating that the Sixth Circuit's decision was contrary to Armstrong and threatened the performance of a core executive constitutional function.

The Court reversed the judgment of the circuit court, stating that the Sixth Circuit's decision was contrary to Armstrong and threatened the performance of a core executive constitutional function.

Who won?

The United States prevailed in the case because the Supreme Court found that the respondent failed to provide relevant evidence that similarly situated persons were treated differently.

The United States prevailed in the case because the Supreme Court found that the respondent failed to provide relevant evidence that similarly situated persons were treated differently.

You must be