United States v. Davila (2012)
- Docket
- 12-167
- Decided
- 2012-01-01
Summary
Question: Did the magistrate judge's improper participation in a plea discussion warrant vacating the defendant's guilty plea? Conclusion: No. Justice Ruth Bader Ginsberg delivered the opinion for the 7-2 majority. The Court held that a judge's improper participation in plea discussions does not belong in the "highly exceptional" category of errors that trigger an automatic reversal of a defendant's guilty plea. Instead, such misconduct falls within the category of "harmless error." Because Davila failed to raise the issue of the magistrate judge's comments at his hearing, he had the burden to show that, but for the misconduct, he would not have pled guilty. In this case, the three-month window between Davila's conversation with the magistrate and his guilty plea de-emphasized the role of the judge's comments in affecting the plea. Justice Antonin Scalia wrote an opinion concurring in part and concurring in the judgment. He argued that the case could be decided based simply on the text of the harmless error rule, which states that a harmless error is one that "does not affect substantial rights." According to Scalia, the majority's analysis of legislative history to discern the scope of the harmless error rule was unnecessary. Justice Clarence Thomas joined in the partial concurrence and concurrence in judgment.