United States v. Alphonso Vonn (535 U.S. 55)
U.S. Supreme Court · decided March 4, 2002 · Supreme Court Database (Spaeth)
- Citation
- 535 U.S. 55 · 122 S. Ct. 1043
- Decided
- March 4, 2002
- Term
- October Term 2001
- Vote
- 8–1
- Majority author
- Justice Souter
- Issue area
- Criminal Procedure
- Disposition
- Vacated and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice Souter delivered the opinion of the Court. The Government avoids reversal of a criminal conviction by showing that trial error, albeit raised by a timely objection, affected no substantial right of the defendant and was thus harmless. Fed. Rule Crim. Proc. 52(a). A defendant who failed to object to trial error may nonetheless obtain reversal of a conviction by carrying the converse burden, showing among other things that plain error did affect his substantial rights. Fed. Rule Crim. Proc. 52(b). Rule 11(h) of the Federal Rules of Criminal Procedure is a separate harmless-error rule applying only to errors committed under Rule 11, the rule meant to ensure that a guilty plea is knowing and voluntary, by laying out the steps a trial judge must take before accepting such a plea. Like Rule 52(a), it provides that a failure to comply with Rule 11 that “does not affect substantial rights shall be disregarded.” Rule 11(h) does not include a plain-error provision comparable to Rule 52(b). The first question here is whether a defendant who lets Rule 11 error pass without objection in the trial court must carry the burdens of Rule 52(b) or whether even the silent defendant can put the Government to the burden of proving the Rule 11 error harmless. The second question is whether a court reviewing Rule 11 error under either standard is limited to examining the record of the…
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