United States v. Davila
133 S. Ct. 2139
| SCOTUS | 2013Background
- Davila was indicted on multiple counts for tax fraud and conspiracy to defraud the United States.
- Davila requested new counsel, alleging his appointed attorney offered no defense strategy and urged a guilty plea.
- A Magistrate Judge held an in camera hearing with Davila and his attorney, but no government representative present.
- During the hearing, the Magistrate Judge urged Davila to plead guilty and suggested cooperation for a sentencing benefit.
- Three months later, Davila pled guilty to a conspiracy count in a district court after a Rule 11 colloquy.
- Davila later moved to vacate the plea and dismiss the indictment, arguing the pre-plea exhortations violated Rule 11(c)(1); the District Court found the plea knowing and voluntary, and the Eleventh Circuit required automatic vacatur under circuit precedent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 11(c)(1) violation warrants automatic vacatur. | Davila argues automatic vacatur is required. | Davila argues prejudice must be shown under Rule 11(h). | No automatic vacatur; require prejudice under Rule 11(h). |
| Whether Rule 11(h) harmless-error standard governs this pre-plea exhortation. | Harmless-error standard should apply. | Plain-error or prejudice should be assessed; automatic vacatur unnecessary. | Rule 11(h) governs assessment of prejudice, not automatic vacatur. |
| Whether, on remand, the full-record shows Davila was prejudiced by the pre-plea exhortations. | Exhortations could have influenced the decision to plead guilty. | District and Magistrate conduct should be evaluated with full record for prejudice. | Proceed to full-record prejudice assessment on remand; not automatic vacatur. |
| Whether the error is structural or subject to harmless-error review. | Rule 11(c)(1) violation is highly intrusive and warrants automatic relief. | Not a structural error; falls within harmless-error framework. | Rule 11(c)(1) error is not structural; governed by harmless-error inquiry. |
Key Cases Cited
- United States v. Vonn, 535 U.S. 55 (2002) (harmlessness standard in Rule 11(h) context when error raised on appeal)
- United States v. Dominguez Benitez, 542 U.S. 74 (2004) (plain-error standard governs Rule 11 error raised on appeal to show prejudice)
- United States v. Marcus, 560 U.S. 258 (2010) (structural vs non-structural errors; context of Rule 11(c)(1) prophylactic rule)
- Neder v. United States, 527 U.S. 1 (1999) (defining structural errors; not applicable to Rule 11(c)(1) here)