June 23, 2017: 30th anniversary of 1st Circuit decision in U.S. v. Daniels

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On June 23, 1987, the US Circuit Court of Appeals for the First Circuit handed down a decision authored by now US Supreme Court Justice Stephen Breyer in United States v. Daniels. Charlie Gilbert represented Appellant Daniels. The appeals court held that the trial court had committed error by refusing to allow the Appellant to withdraw his guilty plea because the full terms of the plea agreement had not been fully disclosed to the court, as required by Rule 11 of the Criminal Rules. The omitted disclosure was the government’s position that all of the defendants had to plead guilty or none could, thus setting the stage for the other defendants to pressure this defendant to plead guilty. Therefore, the guilty plea may not have been voluntary as required by Rule 11, and the defendant should have been allowed to withdraw it.