Brady v. United States

Defendant, after learning his co-defendant would plead guilty and testify against him, pleaded guilty to kidnapping charges to avoid the death penalty. Defendant later argued his plea was coerced. The Court determined that pleas of guilty must be voluntary, knowing, and intelligent. While conceding that the government may not use actual or threatened physical harm or mental coercion to overbear the will of the defendant, the Court found that guilty pleas that are voluntary, knowing, and intelligent are permitted. The Court noted that guilty pleas hold hazards for the innocent and stated that they would have “serious doubts” about plea bargaining if offers of leniency substantially increased the likelihood of false pleas by innocent defendants with competent counsel. But the Court concluded, without any empirical support, that such would not occur if courts satisfied themselves that pleas were voluntarily and intelligently made with adequate advice of counsel and that the defendant’s admissions were accurate and reliable. The Court concluded that while Brady’s plea may have been motivated by a desire to avoid the death penalty, the plea was voluntary, intelligent, and truthful.

This is not to say that guilty plea convictions hold no hazards for the innocent or that the methods of taking guilty pleas presently employed in this country are necessarily valid in all respects. This mode of conviction is no more foolproof than full trials to the court or to the jury. Accordingly, we take great precautions against unsound results, and we should continue to do so, whether conviction is by plea or by trial. We would have serious doubts about this case if the encouragement of guilty pleas by offers of leniency substantially increased the likelihood that defendants, advised by competent counsel, would falsely condemn themselves. p.757-758