Brady v. United States (397 U.S. 742): Facts, Issue, and Reasoning

Subject: Law
Pages: 1
Words: 403
Reading time:
2 min
Study level: College
  • Case: Brady v. the United States was a case that was decided on May 4, 1970, by the United States Supreme Court.
  • Facts: Robert M. Brady was convicted in 1959 of abducting and failing to free a hostage unharmed in contravention of 18 U.S.C.S. § 1201(a), which imposes a maximum penalty of execution if approved by the jury. Joseph J. Connolly, Erwin Griswold, Marshall Tamor Golding, Jerome M. Feit, and Assistant Attorney General Wilson represented the United States. On the other hand, Peter J. Adang, a competent counsel appointed by the Court, represented the petitioner throughout the case. Brady initially pled not guilty to the charges leveled against him. The petitioner also made little effort to avoid the death penalty by foregoing a jury trial due to the trial judge’s unwillingness to prosecute the lawsuit without a jury (Brady v. United States, 1970). However, Brady later changed his mind and pled guilty after discovering that his codefendant would testify against him as a state witness after pleading guilty. The petitioner invoked 28 U.S.C. § 2255 to pursue post-conviction relief by arguing that his guilty plea had been involuntarily given because § 1201 (a) coerced his plea. Brady also insisted that the counsel had pressured him impermissibly and misled him about the possibility of clemency or sentence reduction, and this invalidates his admission of guilt. However, the Court insisted that the petitioner pleaded guilty voluntarily due to his fears of facing capital punishment.
  • Issue: Does the admission of guilt to avoid capital punishment invalidate post-conviction relief under 28 U.S.C. § 2255 to the petitioner?
  • Holding: Yes.
  • Reasoning: The petitioner had initially pled not guilty based on the presumption that his codefendant would also deny the charges, and the trial judge at the lower court would not involve a jury in the case. This is crucial because the petitioner understood that the jury had the power to recommend the death penalty under 18 U.S.C.S. § 1201(a), and the jury’s absence would protect him from execution if found guilty. After understanding that his codefendant would testify against him, the change of mind demonstrates Brady’s awareness of the consequences of the committed crime and implicates Brady’s roles in the issue. Most importantly, pleading not guilty was a deliberate attempt to escape punishment through the death penalty. Consequently, the petitioner’s guilty plea is not invalid because it was intelligently and voluntarily made, and the court’s decision was affirmed.


Brady v. United States, 397 U.S. 742 (1970).