United States v. CARVAJAL, 1:24-cr-00097

Andrew Carvajal was charged with four misdemeanors related to his conduct at the U.S. Capitol on January 6, 2021, including entering restricted grounds and disorderly conduct.
Carvajal pleaded not guilty but later indicated his intent to accept a plea deal after plea negotiations with the government.
During his plea hearing, Carvajal was unable to recall details necessary to support the guilty plea, leading to a delay in finalizing the plea.
On January 21, 2025, the government moved to dismiss the charges with prejudice, citing a presidential Proclamation pardoning certain January 6-related offenses and directing dismissal of such cases.
Carvajal consented to the government's motion, and the court was required to determine if dismissal under Fed. R. Crim. P. 48(a) was appropriate.
The court granted the government's motion to dismiss with prejudice, vacating further proceedings and closing the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether charges should be dismissed with prejudice	Presidential Proclamation requires dismissal	Consents to dismissal due to Proclamation	Dismissal granted with prejudice
Court's discretion under Rule 48(a)	Executive has exclusive discretion	No objection	Court defers to Executive discretion
Need for factual/legal basis for dismissal	Relies on Proclamation as sole basis	Consents to reasoning	No further explanation required
Impact on historical record of January 6 events	N/A	N/A	Dismissal does not alter historical record

United States v. Ammidown, 497 F.2d 615 (D.C. Cir. 1973) (establishes court's role and discretion in granting leave to dismiss charges under Rule 48(a))
United States v. Nixon, 418 U.S. 683 (1974) (recognizes executive branch's exclusive authority over prosecution decisions)
Rinaldi v. United States, 434 U.S. 22 (1977) (notes that Rule 48(a) vests some discretion in court over dismissals, even when defendant consents)