United States v. Jackson
Encyclopedia
United States v. Jackson, was a United States Supreme Court
decision that ruled part of the Federal Kidnapping Act
unconstitutional.
the Congress decided to adopt a federal kidnapping statue. It was designed to allow federal authorities to step in during kidnappings. The Congress believed that federal agents would be more effective than local authorities. The act held that anyone who knowingly transports any person who is unlawfully kidnapped and held for ransom shall be punished by death if the kidnapped person is not liberated unharmed and the jury recommends it.
On October 10, 1966 a federal grand jury in Connecticut returned an indictment charging the defendant under the Act. The District Court for the District of Connecticut dismissed the count of the indictment holding the Federal Kidnapping Act is unconstitutional because it makes the risk of death the price for asserting the right to a jury trial. It reasoned that it impairs the free exercise of the sixth amendment.
The court also objected to the issue raised by the District Court. If a defendant were to plead guilty there would be no way to sentence than to death. However if the defendant attempted an acquittal he would be risking his life if the jury found him guilty. The majority found that the “inevitable effect of any such provision is, of course, to discourage assertion of the Fifth Amendment right not to plead guilty and to deter exercise of the Sixth Amendment right to demand a jury trial.
However the majority disagreed with the District Court’s assertion that the Federal Kidnapping Act fails entirely because its penalty clause is deficient. The court determined that the part of the Act which details punishment is severable from the rest of the act. The judgment of the District Court was reversed and sent back for further proceedings.
in which the court reinforced its decision that not all guilty pleas entered under the Act were invalid.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
decision that ruled part of the Federal Kidnapping Act
Federal Kidnapping Act
Following the historic Lindbergh kidnapping , the United States Congress adopted a federal kidnapping statute—popularly known as the Federal Kidnapping Act — which was intended to let federal authorities step in and pursue kidnappers once they had...
unconstitutional.
Background
In the wake of the Lindbergh kidnappingLindbergh kidnapping
The kidnapping of Charles Augustus Lindbergh, Jr., was the abduction of the son of aviator Charles Lindbergh and Anne Morrow Lindbergh. The toddler, 18 months old at the time, was abducted from his family home in East Amwell, New Jersey, near the town of Hopewell, New Jersey, on the evening of...
the Congress decided to adopt a federal kidnapping statue. It was designed to allow federal authorities to step in during kidnappings. The Congress believed that federal agents would be more effective than local authorities. The act held that anyone who knowingly transports any person who is unlawfully kidnapped and held for ransom shall be punished by death if the kidnapped person is not liberated unharmed and the jury recommends it.
On October 10, 1966 a federal grand jury in Connecticut returned an indictment charging the defendant under the Act. The District Court for the District of Connecticut dismissed the count of the indictment holding the Federal Kidnapping Act is unconstitutional because it makes the risk of death the price for asserting the right to a jury trial. It reasoned that it impairs the free exercise of the sixth amendment.
Decision of the Court
The decision of the court was delivered by Justice Stewart. The court partially agreed with the District Court. The court objected to the fact the Act stated the defendant “shall be punished…by death…”. Under the law the trial judge is obliged to sentence the defendant to death if the jury recommends it. Sentencing in American courts has long been the right of the sitting judge and not the jury. While the jury may make recommendations the court found that the Congress has overstepped when it gave that power solely to the jury.The court also objected to the issue raised by the District Court. If a defendant were to plead guilty there would be no way to sentence than to death. However if the defendant attempted an acquittal he would be risking his life if the jury found him guilty. The majority found that the “inevitable effect of any such provision is, of course, to discourage assertion of the Fifth Amendment right not to plead guilty and to deter exercise of the Sixth Amendment right to demand a jury trial.
However the majority disagreed with the District Court’s assertion that the Federal Kidnapping Act fails entirely because its penalty clause is deficient. The court determined that the part of the Act which details punishment is severable from the rest of the act. The judgment of the District Court was reversed and sent back for further proceedings.
Dissent
Justice White dissent with Black joining his dissent. While he agrees that some defendants would be coerced by the law White argues because the majority states that not every defendant would be coerced by the law then it should not be ruled unconstitutional. He states that pleas of guilt should be carefully examined before accepted to make sure that they have been coerced by the death penalty power of the jury.Subsequent History
The court revisited the issue of the Federal Kidnapping Act in Brady v. United StatesBrady v. United States
Brady v. United States, , was a case in which the United States Supreme Court refused to hold that enormous sentencing discounts and threats of the death penalty are sufficient evidence of coercion.-Trial:...
in which the court reinforced its decision that not all guilty pleas entered under the Act were invalid.