Mitchell v. United States
Encyclopedia
Mitchell v. United States, is a United States Supreme Court case that considered two
Fifth Amendment
privileges related to a criminal defendant
’s rights against self-incrimination
in a Federal District Court. First, does a defendant who waives the guilty plea also waive the privilege
during the sentencing phase of the trial? Secondly, may an adverse inference be drawn from the defendant's silence when the court is determining facts related to the crime which will affect the severity of the sentence?
to distribute five or more kilograms of cocaine
and pleaded guilty. However, Mitchell reserved the right to contest the drug
quantity under the conspiracy count during her sentencing hearing. She was told before her plea was accepted, that she faced a mandatory minimum sentence of one year in prison
for the conspiracy offense and a mandatory minimum of ten years in prison if the prosecution could prove the amount of cocaine involved was the required five kilograms necessary for the longer sentence. Mitchell was told that by making a guilty plea she was waiving her Fifth Amendment
right to remain silent during the trial.
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.
Fifth Amendment
Fifth Amendment to the United States Constitution
The Fifth Amendment to the United States Constitution, which is part of the Bill of Rights, protects against abuse of government authority in a legal procedure. Its guarantees stem from English common law which traces back to the Magna Carta in 1215...
privileges related to a criminal defendant
Defendant
A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...
’s rights against self-incrimination
Self-incrimination
Self-incrimination is the act of accusing oneself of a crime for which a person can then be prosecuted. Self-incrimination can occur either directly or indirectly: directly, by means of interrogation where information of a self-incriminatory nature is disclosed; indirectly, when information of a...
in a Federal District Court. First, does a defendant who waives the guilty plea also waive the privilege
Privilege
A privilege is a special entitlement to immunity granted by the state or another authority to a restricted group, either by birth or on a conditional basis. It can be revoked in certain circumstances. In modern democratic states, a privilege is conditional and granted only after birth...
during the sentencing phase of the trial? Secondly, may an adverse inference be drawn from the defendant's silence when the court is determining facts related to the crime which will affect the severity of the sentence?
Circumstances
Amanda Mitchell was indicted, along with co-defendants, for one count conspiracyConspiracy (crime)
In the criminal law, a conspiracy is an agreement between two or more persons to break the law at some time in the future, and, in some cases, with at least one overt act in furtherance of that agreement...
to distribute five or more kilograms of cocaine
Cocaine
Cocaine is a crystalline tropane alkaloid that is obtained from the leaves of the coca plant. The name comes from "coca" in addition to the alkaloid suffix -ine, forming cocaine. It is a stimulant of the central nervous system, an appetite suppressant, and a topical anesthetic...
and pleaded guilty. However, Mitchell reserved the right to contest the drug
Drug
A drug, broadly speaking, is any substance that, when absorbed into the body of a living organism, alters normal bodily function. There is no single, precise definition, as there are different meanings in drug control law, government regulations, medicine, and colloquial usage.In pharmacology, a...
quantity under the conspiracy count during her sentencing hearing. She was told before her plea was accepted, that she faced a mandatory minimum sentence of one year in prison
Prison
A prison is a place in which people are physically confined and, usually, deprived of a range of personal freedoms. Imprisonment or incarceration is a legal penalty that may be imposed by the state for the commission of a crime...
for the conspiracy offense and a mandatory minimum of ten years in prison if the prosecution could prove the amount of cocaine involved was the required five kilograms necessary for the longer sentence. Mitchell was told that by making a guilty plea she was waiving her Fifth Amendment
Fifth Amendment to the United States Constitution
The Fifth Amendment to the United States Constitution, which is part of the Bill of Rights, protects against abuse of government authority in a legal procedure. Its guarantees stem from English common law which traces back to the Magna Carta in 1215...
right to remain silent during the trial.
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.
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. 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