Bender v. United States

283 F. Supp. 53, 1968 U.S. Dist. LEXIS 7802
CourtDistrict Court, D. Massachusetts
DecidedApril 11, 1968
DocketCiv. A. No. 67-449-C
StatusPublished

This text of 283 F. Supp. 53 (Bender v. United States) is published on Counsel Stack Legal Research, covering District Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bender v. United States, 283 F. Supp. 53, 1968 U.S. Dist. LEXIS 7802 (D. Mass. 1968).

Opinion

OPINION

CAFFREY, District Judge.

This matter came on for hearing on remand from the Court of Appeals, 1 Cir., 387 F.2d 628, on the basis of a petition filed under 28 U.S.C.A. sec. 2255. The crux of the matter and the only issue on which petitioner offered evidence consists of a contention by petitioner that he was “tricked” by one of his attorneys into executing and filing a stipulation during the criminal trial, on the understanding that in exchange therefor he would be granted probation if found guilty by the jury. It is claimed that [54]*54the alleged trickery violated his rights to due process of law under the Fifth Amendment and other constitutionally guaranteed rights of the petitioner.

Petitioner Bender was indicted on December 7,1965, in a one-count indictment which charged him with violation of 18 U.S.C.A. sec. 876, willfully and knowingly depositing in an authorized depository for mail matter an envelope and letter which contained a threat to injure the person of the addressee. He was tried before another judge of this court and a jury on September 13, 15 and 16, 1966, and upon being found guilty was sentenced on October 5, 1966 to the custody of the Attorney General for study pursuant to the provisions of 18 U.S.C.A. 4208(b). Thereafter, on January 10, 1967, he was sentenced to the custody of the Attorney General for a period of three years, pursuant to the provisions of 18 U.S.C.A. 4208(a) (2). He is presently serving this sentence.

The stipulation, the execution of which is under attack herein, was introduced into evidence at the trial as Govt. Exhibit #1. It reads as follows:

“For the purposes of the above case it is hereby stipulated and agreed as follows:
1. That the letter and envelope attached hereto and marked ‘A’ and ‘B’ respectively were written by the defendant, Richard Eugene Bender, on July 28, 1965.
2. That the material attached hereto and marked ‘C’ is an accurate copy of the letter and envelope attached hereto and marked ‘A’ and ‘B.’
3. That on or about July 29, 1965, the defendant, Richard Eugene Bender, deposited the letter and envelope attached hereto and marked ‘A’ and ‘B’ respectively in an authorized depository for mail matter to be sent and delivered by the Post Office Department, knowing that he was so doing.”

The effect of this stipulation was to establish two of the three essential elements of the Government’s case, leaving the Government to its proof of the one remaining essential element, i. e., that the letter in question was “threatening” within the meaning of 18 U.S.C.A. sec. 876.

At the hearing on this 2255 petition, Michael B. Keating, Esq., the third attorney appointed by this court to represent Bender since and in connection with his indictment and related litigation, called as witnesses Norman A. Hubley, Esq., the first of Bender’s court-appointed counsel, who represented him at the criminal trial and until shortly before he was sentenced; Mrs. Frances C. Kissell, the Assistant United States Attorney who prosecuted the case; and the petitioner. Daniel B. Bickford, Esq., the second of Bender’s court-appointed counsel, who represented him on the occasion of the imposition of sentence, was present within the bar enclosure during the entire hearing but was not called as a witness. After hearing, I find and rule as follows:

Norman A. Hubley is an experienced practicing attorney who served approximately four years as an Assistant United States Attorney in the office of the United States' Attorney for the District of Massachusetts, and thereafter entered private practice in Boston with one of the city’s leading law firms in which he is now a partner. Upon being appointed as counsel for Bender, Mr. Hubley obtained a copy of the indictment, examined it, thereafter interviewed Bender with reference to the matter, and conferred with him on several occasions prior to the trial.' On the basis of his not inconsiderable experience as a prosecutor and trial attorney, and in the light of an admission made to him by Bender that Bender had in fact written and mailed the letter in question, Mr. Hubley decided that the best strategy to be pursued in the interests of the defendant in this particular trial was to maneuver the Assistant United States Attorney into requesting Bender to stipulate to the writing and mailing of the letter if this could be done. Mr. Hubley’s reasons for taking this tack [55]*55were that to do so would remove from the case the jury impact of several live witnesses, particularly a handwriting expert whose testimony Mr. Hubley believed would establish the fact already conceded to him by Bender, namely, that Bender had written the letter, and whose testimony, coupled with the illustrative charts, etc. normally used by handwriting experts, would, in Mr. Hubley’s opinion, favorably impress a jury. The stipulation would also eliminate as live witnesses the addressee of the letter and his secretary who had actually received the letter from the postman. In Mr. Hubley’s opinion, this would tend to “low key” the Government’s presentation of its case against Bender. Mr. Hubley felt that the elimination of these live witnesses from the trial would result in a presentation by the Government to the jury of a caliber he considered to be “low key,” with the result that the jury would be free to concentrate its attention on the remaining issue, namely, was the letter a threatening letter? Mr. Hubley felt that if the defendant portrayed himself as a “good guy” who conceded to the jury the writing and mailing, the jury would evaluate the defendant as being a candid type person and would consequently be more likely to believe defense arguments that the letter was not threatening and was not intended by Bender to be threatening. Mr. Hubley also felt that if the Government was obliged to bring a handwriting expert from Washington to testify, the jury might get the impression that the Government considered the case a very serious matter, with the concomitant risk from Bender’s point of view that the jury might also consider it a more serious case than they would were it prosecuted in a “low key” fashion.

I find that Mr. Hubley explained this strategy to Bender on several occasions and that he discussed it with him thoroughly. I believe Mr. Hubley’s testimony that, if possible, he over-explained it to Bender. I further find that prior to discussing this strategy Mr. Hubley explained to Bender what the essential elements of the Government’s case were and that he explained to Bender that the Government was under a legal obligation to prove those essential elements beyond a reasonable doubt. He likewise explained to Bender the nature and operation of a stipulation in a trial and advised him that he was under absolutely no legal obligation whatsoever to stipulate to anything if he elected not to do so and that he had every legal right to put the Government to its proof. Mr. Hubley further explained that whether or not to stipulate was a matter within Bender’s own personal control and that whether or not to stipulate was a matter for Bender to decide in light of Mr. Hubley’s explanation of the reasons why he felt that it was good trial strategy to do so.

Mr.

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Related

Charles White v. Parker L. Hancock, Warden
355 F.2d 262 (First Circuit, 1966)
Richard E. Bender v. United States
387 F.2d 628 (First Circuit, 1967)
Kinney v. United States
177 F.2d 895 (Tenth Circuit, 1949)

Cite This Page — Counsel Stack

Bluebook (online)
283 F. Supp. 53, 1968 U.S. Dist. LEXIS 7802, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bender-v-united-states-mad-1968.