Supreme Court Rules Regarding Broken Plea Bargains
In a vote of 7-2 in the case of Puckett v. United States , the Supreme Court ruled on Wednesday that where federal prosecutors violated a plea bargain with an accused, the violation must be preserved at the trial court level to avoid the application of Rule 52(b). James Puckett was indicted for bank robbery in July 2002. He later negotiated a plea agreement with the government in which he agreed to plead guilty in return for the government agreeing to a reduction in his guideline offense level for acceptance of responsibility and a sentence at the lowest end of the applicable guideline range. Prior to sentencing, however, Puckett assisted in a scheme to defraud the postal service. When sentencing took place, the government opposed any reductions in Puckett's offense level for acceptance of responsibility. The district court then determined that even if it could grant the reduction, it would not. At no time did Puckett's counsel object to the government's new position.