United States v. Davila

PETITIONER: United States
RESPONDENT: Anthony Davila
LOCATION: United States District Court for the Southern District of Georgia

DOCKET NO.: 12-167
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Eleventh Circuit

CITATION: 569 US (2013)
GRANTED: Jan 04, 2013
ARGUED: Apr 15, 2013
DECIDED: Jun 13, 2013

ADVOCATES:
Eric J. Feigin - for the petitioner
Robert M. Yablon - for the respondent

Facts of the case

In early 2010, Anthony Davila was tried for defrauding the federal government by filing false tax returns. During a hearing before the magistrate judge, Davila requested to discharge his court-appointed attorney. Davila was concerned that the attorney had not discussed any possible trial strategies with him; the attorney merely insisted that Davila plead guilty. The magistrate judge explained to Davila that there might not be another viable option and that pleading guilty may be the best advice his attorney could have given him. Following the judge's advice, Davila plead guilty and was subsequently sentenced to 115 months imprisonment.

Davila appealed to the United States Court of Appeals for the Eleventh Circuit. Davila argued that the magistrate judge's advice to plead guilty warranted a new trial. Under the Federal Rules of Criminal Procedure, the court must not be involved in any plea discussions. Since the judge commented on the weight of the evidence against Davila and suggested that a guilty plea would result in a more lenient sentence, he participated in such a plea discussion. As a result of this violation, Davila claimed that the court should vacate the judgment. The appellate court agreed with Davila, vacated the judgment, and remanded the case for further proceedings.

Question

Did the magistrate judge's improper participation in a plea discussion warrant vacating the defendant's guilty plea?

Media for United States v. Davila

Audio Transcription for Oral Argument - April 15, 2013 in United States v. Davila

Audio Transcription for Opinion Announcement - June 13, 2013 in United States v. Davila

John G. Roberts, Jr.:

Justice Ginsburg has our opinion this morning in case 12-167, United States versus Davila.

Ruth Bader Ginsburg:

Rule 11 of the Federal Rules of Criminal Procedure governs guilty pleas.

This case involves two parts of that rule.

The first, Rule 11(c)(1) bars judges from participating in plea negotiations.

The second, Rule 11(h) states, a variance from the requirements of Rule 11 is harmless error if does not affect the defendant's substantial rights.

Anthony Davila, respondent here, was indicted on multiple federal tax fraud charges.

Early on he wrote to the U.S. District Court expressing dissatisfaction with his court appointed attorney because he offered no defensive strategy but simply advised Davila to plead guilty.

At an in camera hearing with only Davila and his lawyer present, a Magistrate Judge told Davila he would not get another court appointed attorney and said Davila's best course, given the strength of the government's case, was to plead guilty.

Over three months later, Davila pleaded guilty before a U.S. District Court judge.

Under oath Davila affirmed that he had not been pressured to enter the plea.

The plea hearing complied in all respects with Rule 11.

Davila said nothing to the district judge about the in camera hearing before the Magistrate Judge.

On appeal, the Eleventh Circuit, unprompted by Davila, found the transcript of the hearing before the Magistrate Judge as ordering Davila to plead to guilty, all agreed violated Rule 11(c)(1).

Following circuit precedent, the Court of Appeals held that violation of the ban on judicial participation in plea bargaining requires automatic vacatur of a guilty plea whether or not the error was prejudicial.

We granted review to resolve a circuit conflict on this issue.

Does violation of Rule 11(c)(1) require automatic vacatur of a guilty plea as the Eleventh Circuit held or as the government urges must a reviewing court consider case specific facts and circumstances to assess the impact of the error on the defendant's decision to plead guilty?

We hold that the latter inquiry is the one called for by the rule and our decisions. Acknowledging that automatic vacatur is inappropriate for most Rule 11 violations, Davila argues that conduct banned by Rule 11(c)(1) is different.

He distinguishes plea-colloquy omissions from pre-plea exhortations to admit guilt; the former come into play after a defendant has already decided to plead guilty, the latter, before a defendant has made that choice.

Improper judicial involvement in plea discussions, Davila maintains, heightens the risk that a defendant's guilty plea would be the result of coercion and not a genuine exercise of freewill.

But nothing in Rule 11's text indicates that the ban on judicial involvement in plea discussions is more basic than other Rule 11 descriptions.

And nothing in the rule or its history suggest that the ban, if dishonored, requires automatic vacatur without regard to case specific circumstances.

Of overriding importance, the Rule 11(h) specifically designed to stop automatic vacaturs falls for across the board application of the harmless error rule.

Rule 11(c)(1) was adopted as prophylactic measure not one impelled by the Due Process Clause.

Violation of the rule thus does not belong in the highly exceptional category of structural errors that trigger automatic reversal because they undermine the fairness of the entire criminal proceeding.

Instead, in assessing Rule 11 errors, a reviewing court generally should take into account all that transpired in the trial court.

Here, that includes the three- month interval between the hearing before the magistrate judge and Davila's guilty plea, and exemplary plea-colloquy conducted by a district judge and the opportunity Davila had at the plea-colloquy to raise any questions he might have about matters relating to his plea.

Because the appellate court did not engage in a full record assessment of the particular facts of Davila's case, we vacate its judgment.

We decide only that the automatic vacatur rule is incompatible with Rule 11(h) and leave all remaining issues to be addressed by the Court of Appeals on remand.

Justice Scalia has filed an opinion concurring in part and concurring in the judgment in which Justice Thomas joins.

Sarah from Law Aspect

Hi there, would you like to get such a paper? How about receiving a customized one? Check it out https://goo.gl/9aavBA