United States v. Wright
291 F.R.D. 85
E.D. Pa.2013Background
- Rule 11(e)(1)(C) plea agreements were proposed by Government and defendants Wright, Chawla, and Teitelman and were rejected by the Court.
- Defendants were previously convicted at trial on multiple honest-services, mail, and related counts; some counts were later vacated on appeal.
- Third Circuit remanded for a new trial after Skilling v. United States limited the reach of honest-services fraud.
- Defendants sought to resolve by “C” plea agreements providing time-served misdemeanor dispositions.
- The Court conducted a hearing and concluded the “C” plea agreements are unreasonable and should be rejected.
- The Court’s rejection leaves the Government free to proceed to trial or to pursue open guilty pleas under other Rule 11 avenues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court should accept a Rule 11(e)(1)(C) plea despite a proposed time-served sentence | Government argues time served aligns with misdemeanors and is consistent with the new information | Wright/Chawla/Teitelman contend time-served is just and reflects the Senate's intent | Rejected; court rejected the C plea as unreasonable and below guideline expectations. |
| Whether the government’s reliance on new misdemeanor charges as comparators is appropriate | Government relies on new misdemeanor counts to justify time served | Defendants argue comparisons to new charges misstate the indictment and original offenses | Rejected; court found comparison to new misdemeanors inappropriate. |
| Whether the proposed pleas promote deterrence and public interest under 18 U.S.C. § 3553(a) | Government claims lenient sentences would undermine deterrence and public trust | Defendants argue leniency promotes efficiency and closure | Rejected; court found the proposed sentences fail to deter and do not serve public interest. |
Key Cases Cited
- Skilling v. United States, 561 U.S. 358 (U.S. 2010) (limits honest services fraud to bribery/kickback schemes; renders conflict-of-interest theories invalid)
- United States v. Wright, 665 F.3d 560 (3d Cir. 2012) (reverses conviction framework post-Skilling; sustains sufficiency under bribery theory)
- In re Morgan, 506 F.3d 705 (9th Cir. 2007) (requires individualized, on-record reasoning for accepting/rejecting plea agreements)
- United States v. Ruch, 906 F. Supp. 261 (E.D. Pa. 1995) (district court approach to plea negotiations under Rule 11(e)(1)(C))