Supreme Court rules for state on plea agreement case

[JURIST] The US Supreme Court [official website; JURIST news archive] ruled [opinion, PDF] 7-2 Wednesday in Puckett v. United States [Cornell LII backgrounder; JURIST report] that a defendant's claim that the prosecution breached a plea agreement must be raised at trial in order to be reviewable on appeal, according to the plain-error standard under the Federal Rules of Criminal Procedure [Rule 52(b) text]. Justice Antonin Scalia wrote for the majority:

Application of plain-error review in the present context is consistent with our cases, serves worthy purposes, has meaningful effects, and is in any event compelled by the Federal Rules. While we recognize that the Government's breach of a plea agreement is a serious matter, "the seriousness of the error claimed does not remove consideration of it from the ambit of the Federal Rules of Criminal Pro-cedure."
Justice David Souter filed a dissenting opinion, in which Justice John Paul Stevens joined. Souter argued:
Puckett is entitled to relief because he and every other defendant who may make an agreement with the Government are entitled to take the Government at its word. Puckett insists that the Government keep its word, and if we are going to have a plain-error doctrine at all, the Judiciary has no excuse for closing this generally available avenue of redress to Puckett or to any other criminal defendant standing in his shoes.
The ruling affirms a decision [opinion, PDF] by the US Court of Appeals for the Fifth Circuit and resolves a split among the circuits.

 

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