United States v. Edward Lee Bean

564 F.2d 700, 1977 U.S. App. LEXIS 5687
CourtCourt of Appeals for the Fifth Circuit
DecidedDecember 9, 1977
Docket77-5110
StatusPublished
Cited by81 cases

This text of 564 F.2d 700 (United States v. Edward Lee Bean) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Edward Lee Bean, 564 F.2d 700, 1977 U.S. App. LEXIS 5687 (5th Cir. 1977).

Opinion

AINSWORTH, Circuit Judge:

On this appeal, defendant Bean raises two contentions: (1) that the district court abused its discretion in refusing to accept a plea bargain entered into by the prosecutor, the defendant and his attorney; (2) that the second count of the indictment should have been dismissed by the district court because as originally written the indictment failed to adequately inform Bean of the offense charged against him.

Bean was charged on October 22, 1976 with theft of property whose value exceeded $100 in violation of 18 U.S.C. § 661 and with burglary of a habitation in violation of V.T.C.A., Penal Code § 30.02 assimilated under 18 U.S.C. § 13, and subsequently was indicted for both offenses. At the initial arraignment, the defendant, Bean, pleaded not guilty to both counts.

On November 30 a rearraignment was held at the defendant’s request. At this time the court was informed that a plea bargain had been reached between the government prosecutor, the defendant and his counsel. Bean would plead guilty to the theft count and cooperate with the prosecutor in investigating others involved in the burglary. In return the prosecutor would move for a dismissal of the second count— the burglary count. Judge Spears indicated that he was -reluctant to accept the plea because the offense of entering a home at night where people were sleeping was a much more serious offense than the theft of an automobile. The theft count carried a maximum sentence of five years whereas the burglary count carried a sentence of between five and ninety-nine years. Bean was allowed to plead guilty to the first count with the understanding that if the plea bargain was ultimately rejected by the court he would be permitted to withdraw his plea. After further consideration Judge Spears notified the parties that he would not accept the plea bargain. On December 12, 1976 Bean was permitted to withdraw his guilty plea.

Defendant’s attorney then filed a motion objecting to the denial of the plea bargain. The district court denied the motion, stating that the bargain was “contrary to the manifest public interest.” A second motion requested the court to dismiss the second count because the language “felony or theft” failed to adequately inform the defendant of the offense with which he was charged. This motion was also denied with the court instead striking the words “a felony or” from the indictment.

Bean was tried by a jury and convicted on both counts. The trial judge sentenced Bean to serve five years on Count 1 and ten years on Count 2 with the sentences to run concurrently. The court also recommended that Bean receive the benefit of a Drug Abuse Program.

An analysis of the propriety of refusing a plea bargain begins with Rule 11 of the Federal Rules of Criminal Procedure. As enacted in 1966, this Rule attempted to codify existing practices concerning the entry of a plea at arraignment. 1 As plea bargaining became more common in re *702 sponse to the growing caseloads of the courts, the 1974 amendments to the Rule gave explicit recognition to the practice. Rule 11(e) provides a mechanism for sanctioning discussions between the defendant and the prosecutor and for presenting the agreement in open court for approval by the judge. 2

While Rule 11(e) provided guidelines for plea bargaining procedure, 3 the Rule does not contravene a judge’s discretion to reject such a plea. The Rule itself states that “the court may accept or reject the agreement . . . .” Fed.R.Crim.P. 11(e)(2). Indeed, the judge must refuse the plea in the absence of a factual basis for the plea. See Fed.R.Crim.P. 11(f). The drafters of the Rule intended for the judge to retain discretion in accepting plea bargains. The Notes of the Committee on the Judici *703 ary, House Report No. 94-247, state: “The procedure is not mandatory; a court is free not to permit the parties to present plea agreements to it.” 18 U.S.C.A., Federal Rules of Criminal Procedure; Rules 10 to 17.1, at 17. The Notes of the Advisory Committee on Rules also indicate that the acceptance of a plea was a decision for the district judge.

The plea agreement procedure does not attempt to define criteria for the acceptance or rejection of a plea agreement. Such a decision is left to the discretion of the individual judge.

Id. at 26. Those cases that have previously considered courts’ refusals to accept plea bargains have found that the judge has discretion in accepting pleas. See, e. g., United States v. Ellis, 5 Cir., 1977, 547 F.2d 863; United States v. Bisco, 1 Cir., 1975, 518 F.2d 95; United States v. Navedo, 2 Cir., 1974, 516 F.2d 293. See also Hoffman, Pleas of Guilty in the Federal Courts, 22 Prac.Law. 11 (Sept. 1976).

While appellate courts have reviewed the refusals of plea bargains, little attention has been given to the formulation of a standard for the district court’s exercise of discretion. 4 The cases that have occurred often involve the specific requirements found in the Rule itself. Most cases have been concerned with the acceptance of pleas where a doubt exists about the defendant’s actual guilt. See, e. g., United States v. Bisco, 1 Cir., 1975, 518 F.2d 95; United States v. Navedo, 2 Cir., 1974, 516 F.2d 293. A particularly difficult line of cases are those where the defendant wishes to plead guilty while maintaining his innocence. See, e. g., North Carolina v. Alford, 400 U.S. 25, 91 S.Ct. 160, 27 L.Ed.2d 162 (1970). Other cases have concerned the ability of a court to refuse a plea bargain because the plea was not entered in accordance with the time deadlines established by the court. See, e. g., United States v. Ellis, 5 Cir., 1977, 547 F.2d 863.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Papke
Tenth Circuit, 2025
United States v. Deandrea Young
Eleventh Circuit, 2024
United States v. Charles York Walker, Jr.
922 F.3d 239 (Fourth Circuit, 2019)
United States v. Scott
877 F.3d 42 (First Circuit, 2017)
United States v. Sergio Lvette Dickerson
636 F. App'x 506 (Eleventh Circuit, 2016)
United States v. Murphy
591 F. App'x 747 (Eleventh Circuit, 2014)
United States v. Sotolongo
998 F. Supp. 2d 1326 (M.D. Florida, 2014)
United States v. Bp Products North America Inc.
610 F. Supp. 2d 655 (S.D. Texas, 2009)
United States v. Samueli
575 F. Supp. 2d 1154 (C.D. California, 2008)
United States v. Alfred Allen Lee
265 F. App'x 763 (Eleventh Circuit, 2008)
State of Tennessee v. Melissa Ann Layman
214 S.W.3d 442 (Tennessee Supreme Court, 2007)
United States v. Smith
417 F.3d 483 (Fifth Circuit, 2005)
Hoskins v. Maricle
150 S.W.3d 1 (Kentucky Supreme Court, 2004)
State v. Montiel
2004 UT App 242 (Court of Appeals of Utah, 2004)
United States v. Diaz
274 F. Supp. 2d 1225 (D. Utah, 2003)
United States v. Jeter
Fifth Circuit, 2002

Cite This Page — Counsel Stack

Bluebook (online)
564 F.2d 700, 1977 U.S. App. LEXIS 5687, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-edward-lee-bean-ca5-1977.