Facts
The respondent, Paul Lewis Hayes, was indicted for forgery of a check for $88.30. According to the law, a felony of such type requires the term of imprisonment ranging from two to ten years (Bordenkircher v. Hayes, 1978). Hayes, his counsel, and the Commonwealth’s Attorney gathered for a conference with the prosecutor concerning the plea. In the course of plea bargaining, the prosecutor proposed to sentence the respondent for five years in prison if Hayes pleads guilty of forgery.
Also, the prosecutor stated that if the accused pleads not guilty, he will be returned to court and indicted under the Kentucky Habitual Criminal Act. This act imposes a more severe punishment for repeated felonies (Bordenkircher v. Hayes, 1978). Importantly, Hayes had a history of two prior offenses that would have been taken into account by the prosecutor. The process of bargaining showed that Hayes might be sentenced for life if he does not plead guilty of forgery.
The respondent pleaded not guilty, was taken to court, and obtained a life sentence under the Kentucky Habitual Criminal Act. Hayes appealed the court decision by arguing that the prosecutor’s actions were unlawful because he was threatening the respondent with felonies outside the case of the original charge.
Issue
Is the Due Process Clause of the Fourteenth Amendment violated if, in the course of plea bargaining, a state prosecutor threatens the accused to be indicted on more severe charges if the respondent does not plead guilty to the felony of the original charge?
Procedural History
After the decision of sentencing Hayes to life imprisonment under the Kentucky Habitual Criminal Act, the respondent’s objections were rejected by the Kentucky Court of Appeals. Then, Hayes took habeas corpus; his case was viewed by the United States District Court for the Eastern District of Kentucky and rejected due to the recognition of the prosecutor’s actions as constitutional (Bordenkircher v. Hayes, 1978). However, The Court of Appeals for the Sixth Circuit reversed the decision of the District Court. The prosecutor’s reasoning was thought to be vindictive, and the accused was recommended to be charged solely for the initial case of forgery. The case was then brought forward to consider a constitutional issue.
Decision
The United States Supreme Court reversed the case, having reasoned that the actions of the prosecutor during the plea bargaining process were not vindictive.
Reasoning
In response to the issue of the case, the court emphasized that despite the fact that the prosecutor had not initially presented charges concerning repeated felonies, his intentions to do so were clearly stated in the negotiations on plea bargaining. Thus, the terms of the plea agreement were clearly articulated to the defendant, and it was in his right either to plead guilty or to agree to accept the prosecutor’s terms.
In such a way, the court rejects the formulation of the prosecutor’s threatening behavior because both parties were informed about the outcomes of the bargain. It is explained, that the same outcome would occur if the felon was initially charged under the Kentucky Habitual Criminal Act and the recidivist charges were dropped in exchange to plea to forgery.
Moreover, plea bargaining is a crucial element of the contemporary justice system of the USA. It is initiated in the interest of the felons and society. Therefore, the actions of the prosecutor persuaded this vital idea to come to an agreement under the terms that would mutually suffice. Plea negotiations are vastly used in the justice system and recognized by many courts as a useful tool of justice. Under such circumstances, the defendant was not charged for any crime he had not committed.
His prior convictions were a crucial reason to charge him with a more severe sentence, of which he was aware upon plea negotiations. Ultimately, Hayes’ choice to plead not guilty was the basis for the trial to sentencing him to life imprisonment.
Separate Opinions
There were some differences in the opinions concerning this case. Namely, the opinion presented in the Chaffin v. Stynchcombe case indicates that plea bargaining violates a defendant’s right to a trial in general (Bordenkircher v. Hayes, 1978). Therefore, any negotiations prior to the trial are thought to be a violation of the defendant’s rights and might be used as the basis for objections.
Also, according to North Carolina v. Pearce, the opinion was that a prosecutor could not use convictions other than those of the current case to indict a defendant of a more severe felony (Bordenkircher v. Hayes, 1978). However, as the Supreme Court reasons, plea negotiations are mutually advantageous for both parties that want to avoid trial.
Impact on Discretion
The winner of the case is the prosecutor whose actions were found constitutional and legal. The losers are the defendant Hayes and the Court of Appeal that required recognizing the prosecutor’s actions as vindictive. The criminal justice system and its actors benefit from the court’s decision because it contributes to the understanding of the role of plea bargaining rules in the judicial branch of power. The defendant is hurt by the court’s decision because he did not use his chance to accept the bargain terms at the initial stage of the negotiations.
Reference
Bordenkircher v. Hayes, No. 76-1334 (1978).