United States v. Armstrong Case Brief

Why is the case important?

Armstrong was among a group of respondents who sought to challenge the fact that they were being federally prosecuted along racial lines.

Facts of the case

“Christopher Lee Armstrong and others were indicted on federal charges of “”conspiring to possess with intent to distribute more than 50 grams of cocaine base (crack) and conspiring to distribute the same.”” The Federal Bureau of Alcohol, Tobacco, and Firearms had monitored Armstrong and others prior to their indictment and arrest. Armstrong filed a motion for discovery or dismissal, alleging that he was selected for prosecution because he was black. The District Court granted the discovery order. It ordered the government to provide statistics on similar cases from the last three years. The government indicated it would not comply. Subsequently, the District Court dismissed the case. The government appealed. The Court of Appeals affirmed the dismissal. It held that the proof requirements for a selective-prosecution claim do not require a defendant to demonstrate that the government has failed to prosecute others who are similarly situated.”

Question

Whether criminal defendants who pursue selective prosecution claims demonstrate people of other races were not prosecuted for similar crimes.

Answer

Chief Justice Rehnquist, on behalf of the court, wrote the majority opinion which held that it is incumbent upon defendants to demonstrate that people of other races have not been similarly prosecuted.

Conclusion

The Supreme Court of the United States reversed and remanded the appellate court’s judgment that affirmed the district court’s order of dismissal. The Court held that, on the assumption that discovery from the Government in support of a federal criminal defendant’s claim of selective prosecution—on the unjustifiable basis of race, religion, or other arbitrary classification, in violation of the equal protection component of the due process clause of the Federal Constitution’s Fifth Amendment—was available to the defendant if the defendant can make the appropriate threshold showing, then in a case that did not involve direct admissions by prosecutors of discriminatory purpose, the defendant is required to produce some evidence that similarly situated defendants of other races had not been prosecuted, in order to satisfy the discriminatory-effect element of the required threshold showing. Under that standard, the Court ruled, defendants in the case at hand failed to satisfy the threshold showing, by failing to show that the Government had declined to prosecute similarly situated suspects of other races.

  • Case Brief: 1996
  • Petitioner: United States
  • Respondent: Armstrong
  • Decided by: Rehnquist Court

Citation: 517 US 456 (1996)
Argued: Feb 26, 1996
Decided: May 13, 1996