Mitchell v. United States (1999)
Mitchell v. United States | |
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Case history | |
Prior | Sentence affirmed, United States v. Mitchell, 122 F.3d 185 (3d Cir. 1997); certiorari granted, Mitchell v. United States, 524 U.S. 925. |
Subsequent | Sentence vacated, remanded for resentencing, United States v. Mitchell, 187 F.3d 331 (3d Cir. 1999) |
Holding | |
A guilty plea does not waive the Fifth Amendment privilege against self-incrimination at sentencing, and the sentencing court may not draw adverse inferences in determining facts related to the circumstances of the crime and bearing upon the sentence when a defendant invokes it. | |
Court membership | |
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Case opinions | |
Majority | Kennedy, joined by Stevens, Souter, Ginsburg, Breyer |
Dissent | Scalia, joined by Rehnquist, O'Connor, Thomas |
Dissent | Thomas |
Laws applied | |
U.S. Const. amend. V; 18 U.S.C. § 846 |
Mitchell v. United States, 526 U.S. 314 (1999), is a
Circumstances
Amanda Mitchell was indicted, along with co-defendants, for one count of
During the sentencing hearing, the District Court heard testimony from some of Mitchell's codefendants, that the amount of Mitchell's alleged drug sales put her over the five-kilogram threshold. Although Mitchell did not testify in defense of the government's changes regarding the quantity of the drug, her counsel argued that the quantity of cocaine attributable to her for sentencing purposes was less than the threshold. The District Court ruled that as a result of her guilty plea, Mitchell had forfeited the right to remain silent about the crime's details. The District Court accepted the testimony of her co-defendants' that put her over the five-kilogram threshold and that therefore the 10-year minimum sentence was mandated. It also noted that her failure to testify contributed to the court's decision to accept the co-defendants' testimony. The Court of Appeals affirmed this decision.[2]
Decision
The court held that a guilty plea is not also a waiver of the privilege at sentencing. It also held that the trial court may not draw adverse inference by the defendant's silence while facts bearing upon the severity of the sentence are considered.[1] Any inference of the defendant's silence advocates that a court's ruling can be made on assumption. The court's decision supported that a ruling should be made based on facts. In addition, had the court allowed for an inference to be made from silence, suspicions would then inherently supersede and contradict the principle that defendants are innocent until proven guilty.
See also
- List of United States Supreme Court cases, volume 526
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
Footnotes
External links
- Text of Mitchell v. United States, 526 U.S. 314 (1999) is available from: Cornell Justia Oyez (oral argument audio)