United States v. Rebecca Stampe
994 F.3d 767
| 6th Cir. | 2021Background
- Police searched Rebecca Stampe’s home (CI-based warrant), arrested her, and she admitted to large-scale meth distribution and identified Michael Loden as a purchaser; later CI information led to a warrant for Loden.
- Stampe pleaded guilty under a Rule 11(c)(1)(C) pact calling for a 168-month sentence; the agreement allowed the government to inform the court of Stampe’s cooperation in Loden’s case (which might affect sentencing), but did not obligate the government to seek a reduction.
- Shortly before Stampe’s sentencing and near Loden’s trial, the government moved to dismiss all charges against Loden, citing “circumstances apart from evidence of guilt” related to confidential informant misconduct.
- Stampe sought disclosure or in camera review of the materials underlying Loden’s dismissal and moved to withdraw from the plea agreement (while remaining guilty) because she claimed the dismissal eliminated the hoped-for benefit of cooperating against Loden.
- The district court accepted the government’s on-the-record representations that any informant misconduct occurred after Stampe’s arrest and that it had complied with Brady/Giglio/Rule 16 obligations, denied the production/in camera review and denied withdrawal from the plea; the Sixth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Stampe was entitled to disclosure or in camera review of materials underlying co-defendant’s dismissal (Brady/Rule 16) | Dismissal of identical conspiracy charge for Loden raised plausible concern the undisclosed materials are material to Stampe’s defense/sentencing; request warranted review | Government: misconduct occurred after Stampe’s arrest and admissions, so materials are immaterial; government represented on record that it complied with Brady/Giglio/Rule 16 | Court accepted government’s representations and denied production/review; no abuse of discretion |
| Standard for triggering disclosure under Brady/Rule 16 in specific-request contexts | Ritchie and Rule 16 require a plausible or materiality showing; Stampe argued she met it given the dismissal | Government argued Stampe’s showing was speculative and inadequate; district court treated it as speculation | Court noted Ritchie/Rule 16 standards but held government’s on-record compliance showing defeated the request under Hernandez |
| Whether district court should have conducted in camera review despite government representations | Stampe argued review warranted given unusual dismissal and possible relevance | Government urged reliance on its representations; district court found review not required | Sixth Circuit: district court within discretion to rely on prosecutor’s representations; in camera review would not have been required though not per se forbidden |
| Whether Stampe could withdraw from her Rule 11(c)(1)(C) plea agreement (while persisting in plea) | Stampe: dismissal undermined a key purpose of the agreement (potential reduction for cooperation), so she should be allowed to withdraw from the agreement | Government: Rule 11(d)(2)(B) standards and Bashara factors apply; Stampe offered no persuasive alternative standard or showing | Court applied Bashara/Rule 11 factors, found no abuse of discretion in denying withdrawal and accepting the plea agreement |
Key Cases Cited
- Weatherford v. Bursey, 429 U.S. 545 (no general constitutional right to discovery in criminal cases)
- Brady v. Maryland, 373 U.S. 83 (prosecutor must disclose material, favorable evidence)
- United States v. Bagley, 473 U.S. 667 (evidence material if disclosure would create reasonable probability of different outcome)
- Pennsylvania v. Ritchie, 480 U.S. 39 (defendant must make a plausible showing to trigger in camera review/disclosure)
- United States v. Valenzuela-Bernal, 458 U.S. 858 (limits on compelled production of third-party witnesses and related standards)
- United States v. Hernandez, 31 F.3d 354 (6th Cir.) (district court may accept prosecutor’s on-the-record representations about materiality absent indications of misconduct)
- United States v. Conder, 423 F.2d 904 (mere conclusory assertions of materiality under Rule 16 insufficient)
- United States v. Ross, 511 F.2d 757 (discussing Rule 16 discovery showing)—(5th Cir.)
- United States v. Muniz-Jaquez, 718 F.3d 1180 (Rule 16 materiality broader than Brady; relevance to defense preparation)—(9th Cir.)
- United States v. Ellis, 470 F.3d 275 (standards of review for plea withdrawal motions)—(6th Cir.)
- United States v. Bashara, 27 F.3d 1174 (Bashara factors for assessing plea-withdrawal motions)—(6th Cir.)
- United States v. Schuhe, [citation="688 F. App'x 337"] (applying plea-agreement withdrawal principles where defendant sought to set aside plea agreement while persisting in plea)—(6th Cir.)