DOJ-OGR-00021841.jpg
710 KB
Extraction Summary
8
People
7
Organizations
3
Locations
7
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
710 KB
Summary
This page from a legal filing argues that plea agreements made by any U.S. Attorney are binding on the entire U.S. government across all federal districts. It cites several court cases establishing this principle and the related rule that any ambiguities in such agreements must be interpreted against the government. The document concludes by stating that a case named Annabi contradicts this established legal precedent.
People (8)
| Name | Role | Context |
|---|---|---|
| Harvey | Party in a legal case |
Mentioned in the case citation U.S. v. Harvey, 791 F.2d 294.
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| Carter | Party in a legal case |
Mentioned in the case citation U.S. v. Carter, 454 F.2d 426.
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| Young | Party in a legal case |
Mentioned in the case citation Young v. U.S., 953 F.Supp.2d 1049.
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| Little | Party in a legal case |
Mentioned in the case citation Little v. U.S., Nos. 1:08-cr-59, 1:09-cv-822.
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| Annabi | Party in a legal case |
Mentioned as a case that is 'out of step with the law of this Circuit' and 'flips this formulation on its head'.
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| Altro | Party in a legal case |
Mentioned in the case citation In re Altro, 180 F.3d 372.
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| Carmichael | Party in a legal case |
Mentioned in the case citation U.S. v. Carmichael, 216 F.3d 224.
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| Ready | Party in a legal case |
Mentioned in the case citation U.S. v. Ready, 82 F.3d 551, which is quoted in the Carmichael citation.
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Organizations (7)
| Name | Type | Context |
|---|---|---|
| United States | government agency |
Referred to as a party in multiple legal cases, also as the 'United States government' and 'the Government'.
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| United States Attorney | government agency |
Mentioned as the entity that 'negotiates and enters a plea agreement' on behalf of the Government.
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| 4th Cir. | court |
The United States Court of Appeals for the Fourth Circuit, cited for the Harvey and Carter cases.
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| D.S.D. | court |
The United States District Court for the District of South Dakota, cited for the Young case.
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| S.D. Ohio | court |
The United States District Court for the Southern District of Ohio, cited for the Little case.
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| 2d Cir. | court |
The United States Court of Appeals for the Second Circuit, cited for the Altro, Carmichael, and Ready cases.
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| DOJ-OGR | government agency |
Appears in the footer identifier 'DOJ-OGR-00021841', likely referring to the Department of Justice.
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Timeline (7 events)
Locations (3)
| Location | Context |
|---|---|
|
Mentioned in the context of the Young v. U.S. case, where a plea agreement in West Virginia was discussed.
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Mentioned in the context of the Young v. U.S. case, where a plea agreement would bind federal prosecutors in South Da...
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Mentioned in the citation for the Little v. U.S. case (S.D. Ohio).
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Relationships (1)
United States Government
→
adversarial (legal)
→
Various defendants (Harvey, Carter, Young, Little, etc.)
The document cites multiple legal cases where the United States government is the prosecuting party against individual defendants in the context of plea agreements.
Key Quotes (5)
"Whenever a United States Attorney negotiates and enters a plea agreement, it is the Government that ‘agrees’ to whatever is agreed to."Source
— U.S. v. Harvey
(Quoted from a 1986 4th Circuit case to support the argument that a plea agreement binds the entire government.)
DOJ-OGR-00021841.jpg
Quote #1
"[t]he United States government is the United States government throughout all of the states and districts"Source
— U.S. v. Carter
(Quoted from a 1972 4th Circuit case to argue for the nationwide authority and identity of the U.S. government.)
DOJ-OGR-00021841.jpg
Quote #2
"bind[] the United States Attorneys in all other districts"Source
— Little v. U.S.
(Describing the interpretation of a plea agreement in a 2010 S.D. Ohio case, where an agreement was found to be binding on all U.S. Attorneys.)
DOJ-OGR-00021841.jpg
Quote #3
"we determine whether a plea agreement has been breached by looking to the reasonable understanding of the parties and by resolving any ambiguities against the Government."Source
— In re Altro
(Quoted from a 1999 2d Circuit case to state the standard for interpreting plea agreements.)
DOJ-OGR-00021841.jpg
Quote #4
"[W]e ‘construe plea agreements strictly against the Government.’"Source
— U.S. v. Carmichael (quoting U.S. v. Ready)
(Quoted from a 2000 2d Circuit case to reinforce the principle that ambiguities in plea agreements are resolved in favor of the defendant.)
DOJ-OGR-00021841.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (1,716 characters)
Case 22-1426, Document 117, 11/01/2024, 3636586, Page17 of 51
appropriate circumstances, be invoked to estop the United States...”); U.S. v. Harvey, 791 F.2d 294, 303 (4th Cir. 1986) (“Whenever a United States Attorney negotiates and enters a plea agreement, it is the Government that ‘agrees’ to whatever is agreed to.”); U.S. v. Carter, 454 F.2d 426 (4th Cir. 1972) (en banc) (vacating conviction where a plea “bargain was allegedly breached in a neighboring district,” adding that “[t]he United States government is the United States government throughout all of the states and districts”); Young v. U.S., 953 F.Supp.2d 1049, 1069 n.4 (D.S.D. 2013) (plea agreement between defendant and “the United States” in West Virginia would bind federal prosecutors in South Dakota); Little v. U.S., Nos. 1:08-cr-59, 1:09-cv-822, 2010 WL 3942749, at *3 (S.D. Ohio Oct. 7, 2010) (plea agreement between defendant “and the United States of America,” which was “silent as to the effect it may have with respect to other United States Attorneys,” would be interpreted to “bind[] the United States Attorneys in all other districts”).
Annabi is also out of step with the law of this Circuit. It is well-settled that “we determine whether a plea agreement has been breached by looking to the reasonable understanding of the parties and by resolving any ambiguities against the Government.” In re Altro, 180 F.3d 372, 375 (2d Cir. 1999); see also U.S. v. Carmichael, 216 F.3d 224 (2d Cir. 2000) (“‘[W]e ‘construe plea agreements strictly against the Government.’”’) (quoting U.S. v. Ready, 82 F.3d 551, 559 (2d Cir. 1996)).
But Annabi flips this formulation on its head, holding that an ambiguous promise of
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DOJ-OGR-00021841
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