United States v. Goodwin Case Brief

Why is the case important?

Prosecutors intensify charges against respondent Goodwin after he first agrees to plea bargain, and then refuses to plead guilty.

Facts of the case

Question

If a prosecutor intensifies the charges pretrial against a defendant after they first agree to and then refuse to plead guilty, does a presumption arise that they have violated that defendant’s due process rights?

Answer

No. Reverse the conviction and remand.
A presumption of prosecutorial vindictiveness only arises when a reasonable likelihood of vindictiveness exists. Here, it is unreasonable to assume that a prosecutor changing the charges against a defendant pretrial has motives of penalizing the defendant for their plea, and therefore, no presumption arises, and no due process violation has occurred.

Conclusion

The appellate court affirmed defendant’s conviction, vacated the supervised release portion of his sentence, and remanded to the district court for resentencing, limited to a reassessment of the length of defendant’s supervised release and any special conditions imposed during this period. The appellate court held that SORNA did not violate nondelegation principles, as Congress provided an intelligible principle to guide exercise of delegated authority, specified the official designated to do so, and set clear boundaries on that exercise. However, because defendant’s failure to register was not a sex offense, the U.S. Sentencing Guidelines Manual § 5D1.2(b)(2) did not apply. The properly calculated Guidelines range for defendant’s offense was five years. 18 U.S.C.S. § 3583(k) authorized any term of years from five to life. Any supervised release term greater than five years would have to be explained by something other than the currently available five-year Guidelines range on remand. Broad restrictions on defendant’s computers, requirements that he submit to warrantless searches and potential seizures, a bar on contact with minors, very broad restrictions on material that depicted or alluded to sexual activity, and internet use restrictions did not appear to be reasonably related to defendant’s offense, history, and personal characteristics. Requiring defendant to participate in sex offender treatment and mental health counseling also was not properly justified.

  • Case Brief: 1982
  • Petitioner: United States
  • Respondent: Goodwin
  • Decided by: Burger Court

Citation: 457 US 368 (1982)
Argued: Apr 21, 1982
Decided: Jun 18, 1982