United States v. Udeagu
110 F.R.D. 172, 1986 U.S. Dist. LEXIS 25902 (1986)
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Rule of Law:
Under Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11, incriminating statements made by a defendant during a guilty plea allocution are inadmissible for any purpose, including impeachment, at a subsequent trial if the guilty plea is later withdrawn.
Facts:
- A defendant was charged with the federal offenses of heroin importation and possession with intent to distribute.
- On March 10, 1986, the defendant entered a guilty plea to one count of illegal heroin importation.
- During the court proceeding for the plea, the defendant was placed under oath and, with counsel present, described his involvement in the crime in detail.
- Subsequently, the defendant asserted that he was not in fact guilty, and his guilty plea was withdrawn.
Procedural Posture:
- Defendant was charged in a federal trial court with heroin importation and possession with intent to distribute.
- Defendant pled guilty to one count of illegal heroin importation.
- Defendant later filed a motion to withdraw his guilty plea, which the trial court granted.
- In anticipation of trial, Defendant filed a motion in limine to preclude the government from using his sworn statements from the plea allocution for impeachment purposes should he choose to testify.
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Issue:
Does Federal Rule of Evidence 410, in conjunction with Federal Rule of Criminal Procedure 11, prohibit the government from using statements made by a defendant during a withdrawn guilty plea allocution to impeach the defendant's credibility if he testifies at a subsequent trial?
Opinions:
Majority - Weinstein, Chief Judge
Yes. Statements made by a defendant during a withdrawn guilty plea proceeding are inadmissible at a subsequent trial, even for impeachment purposes. The plain language of Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11(e)(6) makes statements from withdrawn pleas inadmissible against the defendant in any civil or criminal proceeding. The only exception provided in the rules is for a subsequent prosecution for perjury or false statement. The court's reasoning is heavily based on legislative intent; Congress explicitly considered and rejected a proposed amendment that would have allowed such statements to be used for impeachment. This rejection demonstrates a clear congressional decision to prioritize the policy of encouraging 'unrestrained candor' in plea negotiations. Allowing impeachment would undermine this policy and render the ability to withdraw a plea 'nugatory,' as the defendant's own admissions would almost certainly lead to a conviction.
Analysis:
This decision solidifies the broad exclusionary protection afforded by FRE 410 and FRCP 11, clarifying that it extends beyond use in the prosecution's case-in-chief to also bar use for impeachment. It distinguishes the protections for plea statements from those for statements obtained in violation of Miranda rights, which can be used for impeachment under Harris v. New York. The ruling reinforces the public policy of encouraging plea bargaining by assuring defendants that their candor during negotiations will not be weaponized against them if the plea is ultimately withdrawn, thereby preserving the integrity and effectiveness of both the plea negotiation and plea withdrawal processes.
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