Plea bargains are a fundamental aspect of the criminal justice system, playing a crucial role in resolving criminal cases efficiently. However, plea bargains are not constitutionally guaranteed to defendants and are often taken for granted as being a normal part of the criminal process. In this blog post, I will explain what a plea bargain is, and share how just a few plea bargain cases shape the procedures of modern plea negotiations and offer defendants protection.
Plea Bargain Definition
Before introducing my list of cases which shape modern day plea bargaining, let’s establish what a plea bargain is. A plea bargain is a negotiated agreement between the prosecution and the defendant in a criminal case. It involves the defendant agreeing to plead guilty or no contest to certain charges in exchange for concessions from the prosecution. These concessions can include reduced charges, a lighter sentence, or other favorable terms.
Plea bargains are not a constitutional right afforded to defendants and are available only through prosecutorial discretion. Plea bargains have become a common way to resolve criminal cases, as they offer benefits for both parties involved. Prosecutors can secure convictions without the uncertainty of a trial, while defendants may receive more lenient sentences than they would if they were found guilty at trial.
Top 10 Plea Bargain Cases Influencing Today’s Negotiations
Now, that you are familiar with the definition of a plea bargain, let’s explore the top 10 plea bargain cases influencing the negotiation process and work at protecting the defendant’s rights:
Case #1: Brady v. United States
In Brady v. Maryland, 83 S.Ct. 1194 (1963) the Supreme Court ruled that the prosecution has a constitutional obligation to disclose any evidence that is favorable to the defendant, whether or not the defendant has asked for it. This landmark decision ensures that defendants are aware of any exculpatory evidence that could affect their decision to accept a plea agreement. This decision also forbids the prosecution from inducing a plea by threatening a defendant with physical harm or by mental coercion that overbears a defendant’s will.
Case #2: North Carolina v. Alford
The Alford plea, named after the case of North Carolina v. Alford, 91 S.Ct. 160 (1970), allows defendants to plead guilty while maintaining their innocence. This type of plea bargain is unique because it allows defendants to avoid the risk of a more severe sentence if they were to go to trial, even if they believe they are innocent. The Alford plea is significant because it recognizes the practical realities of criminal cases.
Case #3: Santobello v. New York
In Santobello v. New York, 92 S.Ct. 495 (1971) the Supreme Court emphasized the importance of prosecutorial integrity in plea negotiations. The Court held that when a plea agreement has been breached by the prosecution, the defendant is entitled to specific performance of the agreement or the opportunity to withdraw their guilty plea. This decision protects defendants from unfair tactics during negotiations.
Case #4: Henderson v. Morgan
In Henderson v. Morgan, 96 S.Ct. 2253 (1976), the Supreme Court reaffirmed a plea is not considered voluntary unless the defendant received real notice of the true nature of the charge against him and the consequences he faces. If this knowledge is not conveyed to the defendant, the plea agreement is invalid. This case requires a defendant’s lawyer to explain the charged crimes before permitting the defendant to plead guilty.
Case #5: Bordenkircher v. Hayes
In Bordenkircher v. Hayes, 98 S.Ct. 663 (1978), the Supreme Court upheld the practice of charge stacking during plea negotiations. Charge stacking involves threatening a defendant with more severe charges if they do not accept a plea deal. The Court ruled that this tactic, when used within legal bounds (i.e. evidence exists to support the proposed charges), is not coercive and does not violate a defendant’s rights. This decision has significant implications for how prosecutors approach plea negotiations.
Case #6: Cuyler v. Sullivan
In Cuyler v. Sullivan, 100 S.Ct. 1708 (1980), the Supreme Court ruled the defendant’s guilty plea was open to attack in a federal habeas corpus petition on the ground that counsel did not provide the defendant with reasonably competent advice. In this case, the Court articulated the standard for assessing ineffective assistance of counsel claims based on a conflict of interest stating, In order to demonstrate a violation of his Sixth Amendment rights, a defendant must establish that an actual conflict of interest adversely affected his lawyer’s performance.” This case discourages counsel from representing co-defendants during plea bargaining negotiations.
Case #7: Hill v. Lockhart
In Hill v. Lockhart, 106 S.Ct. 366 (1985), the Supreme Court extended a defendant’s constitutional right to effective assistance of counsel to include the plea bargaining stage. The Court held that the same two-part standard (deficient performance and prejudice) of Strickland v. Washington, 104 S.Ct. 2052 (1984) would apply to ineffective assistance of plea bargaining counsel claims. The Court emphasized the prejudice requirement by stating that a defendant asserting an ineffectiveness claim at the plea stage must show that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial.
Case #8: Puckett v. United States
In Puckett v. United States, 129 S.Ct. 1423 (2009), the Supreme Court reiterated that plea bargains are essentially contracts. Because plea bargains require defendants to waive fundamental constitutional rights, prosecutors are held to meticulous standards of performance made regarding the plea agreement. However, the Court explained that some plea agreement breaches may be curable upon timely objection, for example, where the prosecution simply forgot its commitment and is willing to adhere to the agreement. This case requires a defendant to timely object to any plea agreement breach, or possibly forfeit their argument.
Case #9: Missouri v. Frye
In Missouri v. Frye, 132 S.Ct. 1399 (2012), the Supreme Court ruled that ineffective assistance of counsel during plea bargaining can be a violation of the Sixth Amendment and failing to inform a client of a plea offer will constitute ineffective assistance of counsel. To show that prejudice resulted from such substandard performance, a defendant must demonstrate a reasonable probability that he would have accepted the earlier plea offer had he been afforded effective assistance of counsel and that the end result of the criminal process would have been more favorable by reason of a plea to a lesser charge or a sentence of less prison time. This case requires counsel to inform the defendant when the prosecution extends a plea offer.
Case #10: Lafler v. Cooper
In Lafler v. Cooper, 132 S.Ct. 1376 (2012), the Supreme Court extended the Strickland v. Washington principle by holding that defendants have a right to effective assistance of counsel not only at trial, but also during plea negotiations. When presenting a claim of ineffective assistance of plea counsel, the defendant must show that but for the ineffective advice of counsel there is a reasonable probability that the plea offer would have been presented to the court (i.e., that the defendant would have accepted the plea and the prosecution would not have withdrawn it in light of intervening circumstances), that the court would have accepted its terms, and that the conviction or sentence, or both, under the offer’s terms would have been less severe than under the judgment and sentence that in fact were imposed. This case, and Missouri v. Frye ensure that defendant’s receive effective counsel during plea negotiations.
My Final Thoughts
Plea bargains are a vital part of the criminal justice system, allowing cases to be resolved efficiently while offering benefits to both prosecutors and defendants. Understanding the legal framework and landmark plea bargain cases influencing plea negotiations and agreements is essential for anyone involved in the criminal justice system.
From reviewing these top 10 plea bargain cases, it becomes evident that these cases have had a profound impact on how plea bargains are negotiated, executed and enforced. From disclosure requirements to the right to effective counsel, these decisions shape the way our justice system operates and protects the individuals who enter into plea agreements.
If you, or someone you know, entered into, or are considering entering into, a plea agreement, our book, The Colossal Book of Criminal Citations, contains a section dedicated to the topic of plea agreements. Our books are softcover and institution friendly. Order your copy today, or on behalf of someone incarcerated.