criminal procedure

On February 8, 2010, a magistrate judge held a hearing with the defendant, Anthony Davila, and his attorney. At the hearing, the judge encouraged Davila to plead guilty, and on May 11, 2010, Davila pled guilty to the charges. On appeal, Davila successfully argued that the judge’s encouragement constituted a violation of Federal Rules of Criminal Procedure (“FRCP”) 11(c)(1), which generally prohibits the judge from participating in plea-bargaining. The Supreme Court granted certiorari to determine whether any judicial participation in plea-bargaining, as opposed to “prejudicial” participation, mandates automatic reversal of a conviction. The United States argues that FRCP 11(h) requires the appellate court to review Rule 11 errors under the harmless error standard, while Davila counters that an 11(c)(1) error requires automatic reversal. Furthermore, the United States sees many 11(c)(1) violations as technical and harmless, while Davila views such violations as universally prejudicial, making the government’s role effectively redundant. Both Davila and the United States argue that a ruling for the other party will undermine the finality of guilty convictions secured by plea bargains.

A Michigan court convicted Lloyd Perkins of murder and sentenced him to life in prison. Nearly twenty years later, Perkins is now challenging his conviction based on new evidence supporting his innocence. The lower courts rejected Perkins’ petition for a writ of habeas corpus because of his failure to meet the statute of limitations according to the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”). Perkins maintains that Supreme Court precedent does not require petitioners to reasonably and diligently pursue their underlying constitutional claims to invoke an actual-innocence exception. Perkins also argues that, since traditional equitable principles dictate that courts have the authority to fashion equitable remedies to fill statutory gaps, tolling AEDPA’s one-year statute of limitations does not run contrary to express congressional intent. McQuiggin counters that AEDPA’s one-year statute of limitations cannot be equitably tolled for petitioners who have failed to reasonably and diligently pursue their constitutional claims. Furthermore, McQuiggin argues that courts cannot equitably toll AEDPA’s one-year statute of limitations in Perkins’ case because doing so would alter the express meaning of 28 U.S.C. § 2244(d)(1). This case will determine the responsibilities of federal courts in hearing habeas corpus petitions and define the avenues in which inmates can attempt to prove their innocence. 

The State of Louisiana indicted Jonathan Edward Boyer for the murder of Bradlee Marsh in 2002, but the case did not proceed to trial until 2009. The trial resulted in Boyer’s conviction, and a state appellate court affirmed. Boyer now argues before the Supreme Court that Louisiana violated his Sixth Amendment right to a speedy trial. Specifically, Boyer alleges that five years of delay were caused entirely by Louisiana’s failure to fund his appointed, capitally-certified counsel and that this funding failure should be weighed against the state. Louisiana counters that Boyer has no constitutional right to capitally-certified counsel and that Boyer, not the State, is responsible for the delay. In resolving the question presented, the Supreme Court will determine whether a state’s failure to fund appointed, specially-qualified counsel for an indigent capital defendant should be weighed against the state for speedy trial purposes. The decision may substantially affect indigent defendants’ constitutional rights as well as state procedures for providing indigent capital defense.