Puckett v. United States
2009 United States Supreme Court case
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Puckett v. United States, 556 U.S. 129 (2009), was a United States Supreme Court case in which the court held that Rule 52(b)'s plain error test applies to challenges of whether the prosecutor failed to follow through on a plea bargain, so those challenges generally cannot be made for the first time on appeal.[1][2]
| Puckett v. United States | |
|---|---|
 | |
| Decided March 25, 2009 | |
| Full case name | Puckett v. United States |
| Citations | 556 U.S. 129 (more) |
| Holding | |
| Rule 52(b)'s plain error test applies to challenges of whether the prosecutor failed to follow through on a plea bargain, so those challenges generally cannot be made for the first time on appeal. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Scalia, joined by Roberts, Kennedy, Thomas, Ginsburg, Breyer, Alito |
| Dissent | Souter, joined by Stevens |
| Laws applied | |
| Federal Rules of Criminal Procedure | |
Background
In exchange for petitioner Puckett's guilty plea, the prosecution agreed to request (1) a three-level reduction in his offense level under the Federal Sentencing Guidelines on the ground that he had accepted responsibility for his crimes; and (2) a sentence at the low end of the applicable Guidelines range. The federal District Court accepted the plea.[1]
However, before Puckett was sentenced, he assisted in another crime. As a result, the prosecution opposed any reduction in Puckett's offense level, and the District Court denied the three-level reduction. On appeal, Puckett raised for the first time the argument that by backing away from its reduction request, the Government had broken the plea agreement.[1]
The Fifth Circuit Court of Appeals found that Puckett had forfeited that claim by failing to raise it below; applied Federal Rule of Criminal Procedure Rule 52(b)'s plain-error standard for unpreserved claims of error; and held that, although the error had occurred and was obvious, Puckett had not satisfied the third prong of plain-error analysis in that he failed to demonstrate that his ultimate sentence was affected, especially since the District Judge had found that acceptance-of-responsibility reductions for defendants who continued to engage in criminal activity were so rare as "to be unknown."[1]
Opinion of the court
The Supreme Court issued an opinion on March 25, 2009.[1]
