United States v. Feliciano

998 F. Supp. 166, 1998 U.S. Dist. LEXIS 3525, 1998 WL 133170
CourtDistrict Court, D. Connecticut
DecidedMarch 13, 1998
DocketCrim. 3:97CR204 (PCD)
StatusPublished
Cited by16 cases

This text of 998 F. Supp. 166 (United States v. Feliciano) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Feliciano, 998 F. Supp. 166, 1998 U.S. Dist. LEXIS 3525, 1998 WL 133170 (D. Conn. 1998).

Opinion

RULING ON MOTIONS FOR DISCOVERY OF EVIDENCE IN MITIGATION OF POTENTIAL DEATH PENALTY

DORSEY, District Judge.

Defendants Ruben Feliciano and Ronald Pagan move pursuant to the Fifth, Sixth and Eighth Amendments to the United States Constitution, Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963), 18 U.S.C. § 3592, § 3593, Fed.R.Crim.P. 16, the Standing Order on Pretrial Discovery (“Standing Order”) and the “Court’s supervisory power,” for discovery of evidence in mitigation of a potential death penalty. 1

I. BACKGROUND

Defendants are charged with a violent crime in aid of racketeering in violation of 18 U.S.C. § 1959(a)(5), which provides for a death sentence if convicted. The government has not decided whether to seek the death penalty. At the discovery conference the government notified defense counsel of the opportunity to provide any information the defense deems relevant to the issue of mitigation which the government should consider in determining whether to seek the death penalty. That conference apparently prompted the current motions. The government opposes the motions as premature since it has not decided whether to seek the death penalty. The government also opposes defendants’ specific requests as overbroad.

II. DISCUSSION

A. The Federal Death Penalty-Generally

If the government determines that the circumstances surrounding the commission of a death eligible offense justify a sentence of death, the government must file a Notice of Intent to Seek the Death Penalty “a reasonable time before the trial or before acceptance by the court of a plea of guilty....” 18 U.S-.C. § 3593(a). The notice must set forth the aggravating factors that the government intends to prove as justifying the death penalty. Id. § 3593(a)(2). If the defendant is convicted or pleads guilty, a separate sentencing hearing is required. Id. § 3593(b). At the hearing, any relevant information is permissible including any evidence relating to mitigating or aggravating factors. Id. § 3593(c). See 18 U.S.C. § 3592 (listing aggravating and mitigating factors).

The Department of Justice Manual (“DOJ Manual”) sets forth internal policies and procedures applicable to all federal cases in which a defendant is charged with an offense that carries a potential death sentence. DOJ Manual, § 9-10.000, et seq. (the “Protocol”). Pursuant to the Protocol, the United States Attorney (“USA”) initially reviews the case and decides whether to request approval to seek the death penalty. If the USA decides to request such approval, defendant’s counsel should be informed. DOJ Manual, § 9-10.000B. The USA then submits its recommendation to the Attorney General (“AG”). 2

*169 When submitting a recommendation to the AG, the USA must include “evidence relating to any aggravating or mitigating factors” and “any written material submitted by counsel for the defendant in opposition to the death penalty____” Id. § 9-10.0000. These materials are reviewed by a committee appointed by the AG and “[c]ounsel for the defendant shall be provided an opportunity to present to the Committee, orally or in- writing, the reasons why the death penalty should not be sought.” Id. § 9-10.000D. The committee and the USA review all submissions, and the committee submits a recommendation to the AG, who makes the final determination. Id. § 9-10.000A, § 9-10.000D. 3

Prior to deciding whether to request approval to seek the death penalty the USA “should give counsel for the defendant a reasonable opportunity to present any facts, including any mitigating factors, to the United States Attorney for consideration.” Id. § 9-10.000B. It is this provision of the DOJ Manual that defendants argue entitles them to the requested discovery.

Defendants argue that since the Protocol provides that the defense should be permitted to offer mitigating evidence prior to the USA making a decision regarding the death penalty, they need prompt disclosure of the requested information. Absent early disclosure of this evidence, defendants assert they will be deprived of effective assistance of counsel and a fair decision-making process at this “crucial stage of the prosecution, which will affect not only the penalty, but the conduct of the entire case,” in violation of the Fifth, Sixth and Eighth Amendments. Motion for Discovery of Evidence in Mitigation of Potential Death Penalty (“Motion for Discovery”), p. 3. 4 There is a dearth of caselaw on this issue, which is one of first impression in this circuit.

It has been found that the Protocol “does not create substantive or procedural rights.” United States v. Roman, 931 F.Supp. 960, 964 (D.R.I.1996). Rather, “[t]he protocol articulates internal administrative procedures to be followed by DOJ personnel----” Id. It “provides for ‘standards for determination’ to guide the death penalty decision making process.” Id. (citing DOJ Manual, § 9-10.000G). Accord: United States v. McVeigh, 944 F.Supp. 1478, 1483 (D.Colo.1996) (“the decision to seek the death penalty under the Act is a matter of prosecutorial discretion [and] [t]he Protocol [does] not create any individual right or entitlement____”). Cf. United States v. Craveiro, 907 F.2d 260, 264 (1st Cir.1990), cert. denied, 498 U.S. 1015, 111 S.Ct. 588, 112 L.Ed.2d 593 (1990) (“the internal guidelines of a federal agency, that are not mandated by statute or the constitution, do not confer substantive rights on any party”) (citations omitted); United States v. Loften, 518 F.Supp. 839, 856 (S.D.N.Y.1981), aff'd, 819 F.2d 1130 (2d Cir.1987) (“internal Government policies do not create rights in private citizens. The United States Attorney’s Manual itself specifically states that it is not intended to, does not, and may not be relied upon to, create any rights whatever in any party”). 5

B. The Standing Order!Supervisory Powers

Although the Protocol does not provide a basis to obtain information at this stage, “[a] federal court, guided by considerations of justice, may exercise its supervisory powers to formulate procedural rules not mandated by the Constitution [or statute].” United States v. Ming He,

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Bluebook (online)
998 F. Supp. 166, 1998 U.S. Dist. LEXIS 3525, 1998 WL 133170, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-feliciano-ctd-1998.