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743 KB
Extraction Summary
9
People
3
Organizations
0
Locations
3
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
743 KB
Summary
This legal document excerpt critiques the Second Circuit's interpretation of plea agreements, arguing it misread its own precedent in the 'Papa' case to create an "illogical" rule. This rule is contrasted with United States Supreme Court precedent from cases like 'Santobello' and 'Giglio', which establish that promises made by one prosecutor are binding on other prosecutors within the same office and must be disclosed.
People (9)
| Name | Role | Context |
|---|---|---|
| Gebbie |
Mentioned as having explained that Annabi misread a precedent.
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| Annabi | Party in a legal case |
Cited as a legal case that allegedly misread precedent and created an "illogical" rule.
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| Abbamonte | Party in a legal case |
Cited as a legal case referenced in the Annabi case.
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| Alessi | Party in a legal case |
Cited as a legal case referenced in the Annabi case, which in turn relies on Papa.
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| Papa | Party in a legal case |
Cited as a legal case that the Second Circuit has broadly interpreted regarding plea agreements.
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| Santobello | Party in a legal case |
Cited as a seminal Supreme Court case on plea bargaining.
|
| Giglio | Party in a legal case |
Cited as a Supreme Court case (Giglio v. United States) regarding the duty to disclose promises of immunity.
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| Brady | Party in a legal case |
Referenced in the context of the 'duty under Brady' to disclose information, originating from the Brady v. Maryland c...
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| Assistant United Stated Attorney | Attorney |
Mentioned in the context of the Giglio case, where one AUSA had a duty to disclose a promise made by another AUSA.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Second Circuit | government agency |
Referenced as the court whose rule is being discussed, particularly its interpretation of the Papa case.
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| United States Supreme Court | government agency |
Cited as the authority on plea and immunity agreements, with reference to the Santobello and Giglio cases.
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| United States | government agency |
Mentioned as a party in the case 'Giglio v. United States'.
|
Timeline (3 events)
1971
The Supreme Court ruling in the Santobello case (404 U.S. 257), establishing that a prosecutor's promise in a plea agreement binds other prosecutors in the same office.
The Supreme Court ruling in Giglio v. United States, which held that an Assistant United Stated Attorney had a duty to disclose a promise of immunity made by another AUSA.
Relationships (1)
Assistant United Stated Attorney 1
→
professional
→
Assistant United Stated Attorney 2
The document describes the ruling in Giglio, where one AUSA had a duty under Brady to disclose a promise of immunity that another AUSA had made to a witness, establishing a shared professional responsibility within a prosecutor's office.
Key Quotes (3)
"illogical"Source
— Gebbie
(Used to describe the rule fashioned in the Annabi case.)
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Quote #1
"Papa, however, provides no support for the rule the Second Circuit follows. ... Although Papa held that the plea agreement did not bind other districts because the evidence revealed an intent to bind only one district, the Second Circuit apparently has broadly interpreted this case as meaning that plea agreements do not bind other districts absent an affirmative appearance of doing so. Papa does not explain or attempt to rationalize the rule that has evolved."Source
— Unnamed (cited from 294 F.3d at 547-48)
(A quote from another legal document explaining the Second Circuit's interpretation of the Papa case.)
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Quote #2
"[t]he staff lawyers in a prosecutor’s office have the burden of ‘letting the left hand know what the right hand is doing’ or has done."Source
— United States Supreme Court (in Santobello opinion)
(Explanation from the Santobello case on why a prosecutor's promise binds others in the same office.)
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Quote #3
Full Extracted Text
Complete text extracted from the document (1,751 characters)
Case 22-1426, Document 59, 02/28/2023, 3475902, Page34 of 113
Papa, 533 F.2d 815 (2d Cir. 1976)). But, as Gebbie explained, Annabi misread
this Court’s precedent and fashioned an “illogical” rule out of whole cloth:
this Court’s precedent and fashioned an “illogical” rule out of whole cloth:
The first case cited in Annabi is Abbamonte, but Abbamonte merely
relies upon the other two cases cited in Annabi—Alessi and Papa . . .
relies upon the other two cases cited in Annabi—Alessi and Papa . . .
The court in Alessi relies upon Papa, which is a related case. . . .
Papa, however, provides no support for the rule the Second
Circuit follows. ... Although Papa held that the plea agreement did
not bind other districts because the evidence revealed an intent to bind
only one district, the Second Circuit apparently has broadly
interpreted this case as meaning that plea agreements do not bind
other districts absent an affirmative appearance of doing
so. Papa does not explain or attempt to rationalize the rule that has
evolved.
Circuit follows. ... Although Papa held that the plea agreement did
not bind other districts because the evidence revealed an intent to bind
only one district, the Second Circuit apparently has broadly
interpreted this case as meaning that plea agreements do not bind
other districts absent an affirmative appearance of doing
so. Papa does not explain or attempt to rationalize the rule that has
evolved.
294 F.3d at 547-48 (brackets and italics in original; bold added).
Annabi stands in tension with what the United States Supreme Court has written
about plea and immunity agreements. In Santobello, 404 U.S. 257 (1971)—the
seminal case on plea bargaining—the Supreme Court held that one prosecutor’s
promise in a plea agreement would bind other prosecutors, even those who might
have been unaware of the promise. As Santobello explained, “[t]he staff lawyers
in a prosecutor’s office have the burden of ‘letting the left hand know what the
right hand is doing’ or has done.” 404 U.S. at 262. And in Giglio v. United States,
the Supreme Court held that an Assistant United Stated Attorney (“AUSA”) had a
duty under Brady to disclose a promise of immunity that another AUSA had made
to a testifying witness, even though the first AUSA had been falsely assured that
about plea and immunity agreements. In Santobello, 404 U.S. 257 (1971)—the
seminal case on plea bargaining—the Supreme Court held that one prosecutor’s
promise in a plea agreement would bind other prosecutors, even those who might
have been unaware of the promise. As Santobello explained, “[t]he staff lawyers
in a prosecutor’s office have the burden of ‘letting the left hand know what the
right hand is doing’ or has done.” 404 U.S. at 262. And in Giglio v. United States,
the Supreme Court held that an Assistant United Stated Attorney (“AUSA”) had a
duty under Brady to disclose a promise of immunity that another AUSA had made
to a testifying witness, even though the first AUSA had been falsely assured that
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