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Criminal Law Keyed to Ohlin
United States v. Bailey
Citation:
444 U.S. 394 (1980)Facts
The respondents, Clifford Bailey, James T. Cogdell, Ronald C. Cooley, and Ralph Walker, were federal prisoners at the District of Columbia jail. One morning, they crawled through a window from which a bar had been removed, slid down a knotted bedsheet, and escaped from custody. They were recaptured after they had remained at large for a period of time ranging from one month to three abd a half months. They were all charged with violating 18 U.S.C. § 751 (a).
At trial, each of the the respondents attempted to introduce evidence regarding the various conditions and events at the jail, to present a defense of duress. They testified that guards would set fire to trash, bedding, and other objects in their cells, and subjected them to beatings and to threats of death. The trial court rejected the evidence and did not allow the jury to consider it. The respondents were all convicted.
They appealed, and the Court of Appeals reversed the trial court, concluding that it should have allowed the jury to consider the evidence of coercive conditions in determining whether the respondents had formulated the requisite intent to sustain a conviction under 751(a). It stated that if the respondents were acting out of duress, then they did not act “with an intent to avoid confinement.” The respondents were granted a new trial, and the United States appealed.
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