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Criminal Law Keyed to Kadish
Brady v. United States
Citation:
397 U.S. 742 (1970)Facts
In 1959, Robert Brady was charged with kidnapping in violation of 18 U.S.C. § 1201(a), which carried a potential death penalty if the jury so recommended. Brady initially pleaded not guilty but changed his plea to guilty after learning that his co-defendant had confessed and would testify against him. The trial judge questioned Brady twice about the voluntariness of his plea before accepting it. Brady was sentenced to 50 years’ imprisonment, later reduced to 30 years. In 1967, following the Supreme Court’s decision in United States v. Jackson (which invalidated the death penalty provision of the Federal Kidnapping Act), Brady sought post-conviction relief, claiming his guilty plea was coerced by the threat of the death penalty. The District Court found that Brady’s plea was voluntary and motivated by his co-defendant’s decision to plead guilty, not by the statute’s death penalty provision.
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