McCarthy v. United States
394 U.S. 459 (1969)
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Rule of Law:
A United States district court's failure to comply fully with the procedure in Federal Rule of Criminal Procedure 11 when accepting a guilty plea necessitates setting aside the conviction and allowing the defendant to plead anew. Prejudice is inherent in such a failure, and the defendant is not required to show specific harm.
Facts:
- George McCarthy was indicted on three counts of 'wilfully and knowingly' attempting to evade federal income tax payments for the years 1959, 1960, and 1961.
- McCarthy, who was 65 years old and in poor health, had been suffering from a serious drinking problem during the period he was alleged to have evaded taxes.
- McCarthy agreed to plead guilty to the charge for the year 1960 in exchange for the government's promise to move to dismiss the other two charges.
- During the plea hearing, the judge informed McCarthy of the maximum penalty and that he was waiving his right to a jury trial, but did not personally ask him if he understood the nature of the charge.
- At the subsequent sentencing hearing, McCarthy and his lawyer asserted that his failure to pay taxes was 'not deliberate,' but was 'neglectful' and 'inadvertent,' and that he never had any 'disposition to deprive the United States of its due.'
Procedural Posture:
- George McCarthy was indicted in the United States District Court for the Northern District of Illinois for tax evasion.
- He initially pleaded not guilty but later changed his plea to guilty on one of the three counts.
- The District Judge accepted the plea and entered a judgment of conviction, sentencing McCarthy to one year in prison and a fine.
- McCarthy (appellant) appealed to the United States Court of Appeals for the Seventh Circuit, arguing the plea was accepted in violation of Federal Rule of Criminal Procedure 11.
- The Court of Appeals affirmed the conviction, holding that the District Judge had substantially complied with the rule.
- The United States Supreme Court granted certiorari to resolve a conflict among the circuit courts regarding the consequences of a failure to follow Rule 11.
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Issue:
Does a federal district court's acceptance of a guilty plea without strictly adhering to Federal Rule of Criminal Procedure 11, specifically by failing to personally address the defendant to determine his understanding of the nature of the charge, require that the plea be set aside and the defendant be given the opportunity to plead again?
Opinions:
Majority - Mr. Chief Justice Warren
Yes, a defendant is entitled to plead anew if a United States district court accepts his guilty plea without fully adhering to the procedure provided for in Rule 11. Rule 11 is not a mere formality; it serves two critical purposes: 1) to assist the judge in making the constitutionally required determination that a guilty plea is truly voluntary, and 2) to produce a complete record of the factors relevant to this determination to discourage frivolous post-conviction attacks. A guilty plea is a waiver of fundamental constitutional rights, including the right to a jury trial and the privilege against self-incrimination, which must be knowing and voluntary. For a plea to be truly voluntary, the defendant must possess an understanding of the law in relation to the facts. The 1966 amendment to Rule 11 expressly requires the judge to 'personally' address the defendant to ensure this understanding, and a court cannot simply assume the defendant understands the charge because he is represented by counsel. The proper remedy for noncompliance is not a subsequent evidentiary hearing on voluntariness but allowing the defendant to plead anew, as prejudice is inherent in the failure to follow the Rule's procedural safeguards.
Concurring - Mr. Justice Black
Yes, the judgment of conviction must be reversed. This conclusion is based exclusively on the trial judge's failure to first address the defendant personally, as is explicitly required by the text of Rule 11 of the Federal Rules of Criminal Procedure. The concurrence is not based on the Court's 'supervisory power' over lower federal courts, but solely on the clear violation of the Rule itself.
Analysis:
This decision established a bright-line rule requiring strict compliance with Rule 11 for the acceptance of guilty pleas in federal court. It effectively removed the possibility of a 'harmless error' analysis when a district judge fails to conduct a proper personal colloquy with the defendant. The Court's holding that 'prejudice inheres in a failure to comply' creates an automatic-reversal rule, emphasizing the prophylactic importance of the Rule's procedures. This significantly strengthened defendants' rights during the plea process and forced federal judges to be more meticulous in creating a clear and complete record demonstrating the plea's voluntariness and the defendant's understanding.
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