Ricketts v. Adamson

Supreme Court of United States
483 U.S. 1 (1987)

ELI5:

Rule of Law:

The Double Jeopardy Clause is not violated when a defendant is prosecuted for a greater offense after breaching a plea agreement under which they were convicted of a lesser included offense, as the defendant's voluntary breach of the agreement waives the protection against double jeopardy.

Facts:

John Harvey Adamson was charged with the first-degree murder of Donald Bolles.
Adamson entered a plea agreement with the State of Arizona, pleading guilty to second-degree murder.
In exchange, Adamson agreed to "testify fully and completely" against two other individuals, Max Dunlap and James Robison, who were also involved in the murder.
The agreement specified that if Adamson refused to testify or testified untruthfully, the agreement would be "null and void and the original charge will be automatically reinstated."
Adamson testified against Dunlap and Robison, who were subsequently convicted of first-degree murder.
After Adamson was sentenced for second-degree murder, the convictions of Dunlap and Robison were reversed on appeal, and their cases were remanded for retrial.
When the State requested Adamson's testimony for the retrials, Adamson's counsel informed the prosecutor that Adamson believed his obligation to testify had ended upon his sentencing.
When called to testify in pretrial proceedings for the retrial, Adamson invoked his Fifth Amendment privilege against self-incrimination.

Procedural Posture:

The State of Arizona charged Adamson with first-degree murder in a state trial court.
During jury selection, Adamson pleaded guilty to second-degree murder pursuant to a plea agreement, which the trial court accepted and for which it later imposed a sentence.
After the State deemed Adamson in breach of the agreement, it filed a new information charging Adamson with first-degree murder.
Adamson's motion to quash the information on double jeopardy grounds was denied by the trial court.
On a special action, the Arizona Supreme Court held that Adamson violated the plea agreement, thereby waiving his double jeopardy defense, and it reinstated the original first-degree murder charge.
Adamson was subsequently tried, convicted of first-degree murder, and sentenced to death, a judgment affirmed by the Arizona Supreme Court on direct appeal.
Adamson filed a second petition for a writ of habeas corpus in federal district court, which was dismissed.
The U.S. Court of Appeals for the Ninth Circuit, sitting en banc, reversed the district court, holding that Adamson's double jeopardy rights had been violated, and it directed the issuance of the writ.
The State petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.

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Issue:

Does the Double Jeopardy Clause bar the prosecution of a defendant for first-degree murder after he breaches a plea agreement under which he had already been convicted and sentenced for the lesser included offense of second-degree murder?

Opinions:

Majority - Justice White

No. The Double Jeopardy Clause does not bar the prosecution of respondent for first-degree murder. When a defendant voluntarily breaches a plea agreement, they waive the double jeopardy protection that attached to the initial plea. The terms of the agreement were explicit: a breach by Adamson would render the agreement null and void, returning the parties to the status quo ante. By choosing to stand on his interpretation of the agreement and refuse to testify—a choice that proved erroneous—Adamson knowingly risked the reinstatement of the first-degree murder charge. Citing United States v. Scott, the court reasoned that the Double Jeopardy Clause does not relieve a defendant from the consequences of their voluntary choice. Adamson's breach removed the constitutional bar to prosecution on the greater charge.

Dissenting - Justice Brennan

Yes. The Double Jeopardy Clause bars the prosecution because Adamson never breached his plea agreement. Adamson's interpretation of the agreement—that his testimonial duty ended upon sentencing—was reasonable based on the agreement's language. Advancing a good-faith, albeit erroneous, interpretation of a contract is not an anticipatory repudiation or breach. The State should not have the unilateral power to declare a breach; the dispute should have been resolved by a court first. Furthermore, a waiver of a fundamental right must be knowing and intelligent. Adamson never deliberately chose to breach the agreement; he chose to dispute its meaning, which is not a valid waiver of his double jeopardy rights. Even if a breach occurred, the State failed to mitigate damages, as Adamson offered to testify after the court clarified his obligation, but the State chose instead to prosecute him for a capital offense.

Analysis:

This case establishes that a defendant can prospectively waive double jeopardy protection through the terms of a plea agreement, contingent upon their own future conduct. The decision reinforces the contractual nature of plea agreements, holding that a defendant's voluntary breach can return the parties to their pre-agreement positions, nullifying the jeopardy that attached to the initial guilty plea. This empowers prosecutors to strictly enforce the terms of such bargains. However, the dissent raises significant due process concerns about fairness, arguing that this approach gives the state unilateral power to interpret ambiguous terms and punish a defendant who, in good faith, disputes that interpretation.

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