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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. One morning, they crawled through a window, slid down a knotted bedsheet, and escaped from custody. They were recaptured after they had remained at large for a period of time.
At trial, each of the respondents attempted to introduce evidence to support a duress defense. This evidence centered on the various conditions and events at the jail. They testified that the prison 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, holding that the evidence should have been admitted to allow the jury to decide if the respondents left federal custody voluntarily or not. The Court of Appeals stated that if the respondents were acting out of duress, then they did not act with an intent to avoid confinement. The Government appealed.
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