United States, Petitioner v. Anthony Davila (569 U.S. 597)
U.S. Supreme Court · decided June 13, 2013 · Supreme Court Database (Spaeth)
- Citation
- 569 U.S. 597 · 133 S. Ct. 2139
- Decided
- June 13, 2013
- Term
- October Term 2012
- Vote
- 9–0
- Majority author
- Justice Ginsburg
- Issue area
- Criminal Procedure
- Disposition
- Vacated and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice GINSBURG delivered the opinion of the Court. This case concerns Rule 11 of the Federal Rules of Criminal Procedure, which governs guilty pleas. Two provisions of that rule are key here. The first, Rule 11(c)(1), instructs that "[t]he court must not participate in [plea] discussions." The second, Rule 11(h), states: "A variance from the requirements of th[e] rule is harmless error if it does not affect substantial rights." Rule 52(a), which covers trial court errors generally, similarly prescribes: "Any error ... that does not affect substantial rights must be disregarded." Anthony Davila, respondent here, entered a guilty plea to conspiracy to defraud the United States by filing false income tax returns. He maintains that he did so because a U.S. Magistrate Judge, at a pre-plea in camera hearing and in flagrant violation of Rule 11(c)(1), told him his best course, given the strength of the Government's case, was to plead guilty. Three months later, Davila entered a plea on advice of counsel. The hearing on Davila's plea, conducted by a U.S. District Judge, complied in all respects with Rule 11. The question presented is whether, as the Court of Appeals for the Eleventh Circuit held, the violation of Rule 11(c)(1) by the Magistrate Judge warranted automatic vacatur of Davila's guilty plea. We hold that Rule 11(h) controls. Under the inquiry that Rule instructs, vacatur…
Excerpt of a 27,390-character opinion. The full text and citation network load in the interactive viewer above.