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United States v. Mezzanatto Case Brief

Summary of United States v. Mezzanatto (1995)

Facts: D was set-up by friend to sell drugs to cop. Once arrested, he engaged plea discussions with the government and said he waived his right, under Rule 410, for those discussions to be inadmissible in court.  When he took the stand, the prosecution introduced evidence from those discussions that ? had inconsistent statements;D was then convicted by a jury.  The 9th Circuit reversed stating a Dcould not waive his rights under Rule 410.  Because the 9th Circuit and 7th Circuit conflicted in rulings, the SC took the case and reversed the 9th Circuit.

Issue: Whether a D can waive Rule 410, the inadmissibility of pleas, plea discussions and related statements?

Holding: (Thomas) Yes. The SC has held that a criminal defendant may knowingly and voluntarily waive many of the most fundamental protections afforded by the Constitution.  Absent some affirmative indication that the agreement was entered into unknowingly or involuntarily, an agreement to waive the exclusionary provisions of the plea-statement rules is valid and enforceable.



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