Mitchell v. United States

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Mitchell v. United States

Argued December 9, 1998
Decided April 5, 1999

Full case name:	Amanda Mitchell v. United States of America

Citations:	526 U.S. 314

Holding

A guilty plea is not also a waiver of the Fifth Amendment privilege at sentencing. Further, the trial court may not draw adverse inference if the defendant is silence during consideration of the facts bearing upon the severity of the sentence

Court membership

Chief Justice: William Rehnquist
Associate Justices: John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer

Case opinions

Majority by: Kennedy
Joined by: Breyer, Stevens, Souter, Ginsburg
Dissent by: Scalia
Joined by: O'Connor, Thomas, Rehnquist

Laws applied

U.S. Const. amend. V; 18 U.S.C. § 846

Mitchell v. United States 526 U.S. 314 (1999) is a United States Supreme Court case that considered two Fifth Amendment privileges related to a criminal defendant’s rights against self-incrimination in a Federal District Court. First, does a defendant who waives the guilty plea also waiver the privilege during the sentencing phase of the trial? Secondly, may an adverse inference be drawn from the defendant's silence when the court is determining facts related to the crime which will affect the severity of the sentence?^[1]

1 Circumstances
2 Decision
3 See also
4 Footnotes
5 External links

[edit] Circumstances

Amanda Mitchell was indicted, along with co-defendants, for one count conspiracy to distribute five or more kilograms of cocaine and pleaded guilty. However, Mitchell reserved the right to contest the drug quantity under the conspiracy count during her sentencing hearing. She was told before her plea was accepted, that she faced a mandatory minimum sentence of one year in prison for the conspiracy offense and a mandatory minimum of ten years in prison if the prosecution could prove the amount of cocaine involved was the required five kilograms necessary for the longer sentence. Mitchell was told that by making a guilty plea she was waiving her Fifth Amendment right to remain silent during the trial.^[2]

During the sentencing hearing, the District Court heard testimony from some of Mitchell's codefendants, that the amount of Mitchell's alleged drug sales put her over the five-kilogram threshold. Although Mitchell did not testify in defense of the government's changes regarding the quantity of the drug, her counsel argued that the quantity of cocaine attributable to her for sentencing purposes was less than the threshold. The District Court ruled that as a result of her guilty plea, Mitchell had forfeited the right to remain silent about the crime's details. The District Court accepted the testimony of her co-defendants' that put her over the five-kilogram threshold and that therefore the 10-year minimum sentence was mandated. It also noted that her failure to testify contributed to the court's decision to accept the co-defendants' testimony. The Court of Appeals affirmed this decision.^[2]

[edit] Decision

The court held that a guilty plea is not also a waiver of the privilege at sentencing. It also held that the trial court may not draw adverse inference by the defendant's silence while facts bearing upon the severity of the sentence are considered.^[1]