United States v. Mezzanatto

513 U.S. 196 (1995)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

Shuster was arrested for running a meth lab and agreed to cooperate and a few hours thereafter placed a call to D's pager. When D returned the call, Shuster told him a friend wanted to purchase a pound of meth for $13,000. Shuster agreed to meet D later that day. Shuster introduced the undercover officer as his friend. The officer asked if D had brought the stuff and D told him it was in his car. D produced a brown bag from the car with one pound of meth inside. D then asked the officer if he wanted to take a hit with a pipe that D had produced. The officer told D that he would get him the money first. D was then arrested and charged with possession with intent to distribute. D then asked to meet with the DA to determine if cooperation was in order. As a condition to proceeding the DA told D that any statements he made that were untruthful could be used to impeach him. D, with counsel present, agreed to proceed with the meeting. D made all types of self-serving false and misleading statements, and the meeting was terminated. D was tried and took the stand in his own defense. D denied everything and testified that he was dumb and ignorant and not involved in trafficking and that he had thought that Shuster was making explosives for the CIA and denied knowing that the package he delivered to the undercover officer contained meth. Over defense counsel objections, the DA cross-examined D over the inconsistent statements made during the plea bargain meeting. D denied the statements. The DA called an agent to the stand who was there. D was convicted and appealed. FRE 410 and FRCP 11(e)(6) provide that statements made in the course of plea discussions between a criminal defendant and a prosecutor are inadmissible against the defendant. The court below held that these exclusionary provisions may not be waived by the defendant; D's agreement to allow the statements to be used as impeachment was unenforceable. This appeal resulted, and the Supreme Court granted certiorari to resolve conflicting opinions among the Courts of Appeal.