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724 KB
Extraction Summary
3
People
4
Organizations
1
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal filing / court opinion page
File Size:
724 KB
Summary
This document is page 58 of 80 from a legal filing (likely a brief or opinion) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on July 2, 2021. The text analyzes legal precedents, specifically *Government of Virgin Islands v. Scotland*, to argue that prosecutors must be held to their promises and assurances to defendants, particularly when a defendant relies on those promises to their detriment. The page discusses the concepts of specific performance, due process, and plea agreements.
People (3)
| Name | Role | Context |
|---|---|---|
| Scotland | Defendant (in cited case law) |
Subject of the cited case Government of Virgin Islands v. Scotland (1980).
|
| Prosecutors | Legal officials |
Discussed generally regarding their obligation to hold to their word and promises in plea agreements.
|
| Defendants | Legal parties |
Discussed generally regarding their due process rights and reliance on government promises.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Government of Virgin Islands |
Plaintiff in the cited case law.
|
|
| Circuit Court of Appeals (3d Cir.) |
The court that issued the opinion in the cited Scotland case (1980).
|
|
| District Court |
Lower court mentioned in the Scotland case summary.
|
|
| DOJ |
Department of Justice (indicated in Bates stamp DOJ-OGR).
|
Timeline (2 events)
1980
Decision in Government of Virgin Islands v. Scotland
3rd Circuit Court of Appeals
Locations (1)
| Location | Context |
|---|---|
|
Jurisdiction of the cited case law.
|
Relationships (1)
Text discusses the binding nature of prosecutor assurances to defendants in plea negotiations.
Key Quotes (3)
"when a 'defendant detrimentally relies on the government’s promise, the resulting harm from this induced reliance implicates due process guarantees.'"Source
DOJ-OGR-00004870.jpg
Quote #1
"Prosecutors can be bound by their assurances or decisions under principles of contract law or by application of the fundamental fairness considerations that inform and undergird the due process of law."Source
DOJ-OGR-00004870.jpg
Quote #2
"The law is clear that, based upon their unique role in the criminal justice system, prosecutors generally are bound by their assurances, particularly when defendants rely to their detriment upon those guarantees."Source
DOJ-OGR-00004870.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,104 characters)
Case 1:20-cr-00330-PAE Document 310-1 Filed 07/02/21 Page 58 of 80
rather than on contract law principles. Government of Virgin Islands v. Scotland, 614
F.2d 360 (3d Cir. 1980), is instructive. In that case, the parties had reached a tentative,
preliminary plea agreement. But before the defendant could formally enter the plea, the
prosecutor attempted to add another term to the deal. Id. at 361-62. The defendant
rejected the new term and sought specific performance of the original, unconsummated
agreement. Id. The district court denied his request. The Circuit Court of Appeals
affirmed, holding that, because the agreement was not formalized and accepted by the
court, the defendant was not entitled to specific performance under a contract law theory.
Id. at 362. The appellate court noted that, absent detrimental reliance upon the
prosecutor’s offer, a defendant’s due process rights were sufficiently safeguarded by his
right to a jury trial. Id. at 365. The court cautioned, however, that, by contrast, when a
“defendant detrimentally relies on the government’s promise, the resulting harm from this
induced reliance implicates due process guarantees.” Id. 22
F.2d 360 (3d Cir. 1980), is instructive. In that case, the parties had reached a tentative,
preliminary plea agreement. But before the defendant could formally enter the plea, the
prosecutor attempted to add another term to the deal. Id. at 361-62. The defendant
rejected the new term and sought specific performance of the original, unconsummated
agreement. Id. The district court denied his request. The Circuit Court of Appeals
affirmed, holding that, because the agreement was not formalized and accepted by the
court, the defendant was not entitled to specific performance under a contract law theory.
Id. at 362. The appellate court noted that, absent detrimental reliance upon the
prosecutor’s offer, a defendant’s due process rights were sufficiently safeguarded by his
right to a jury trial. Id. at 365. The court cautioned, however, that, by contrast, when a
“defendant detrimentally relies on the government’s promise, the resulting harm from this
induced reliance implicates due process guarantees.” Id. 22
Considered together, these authorities obligate courts to hold prosecutors to their
word, to enforce promises, to ensure that defendants’ decisions are made with a full
understanding of the circumstances, and to prevent fraudulent inducements of waivers of
one or more constitutional rights. Prosecutors can be bound by their assurances or
decisions under principles of contract law or by application of the fundamental fairness
considerations that inform and undergird the due process of law. The law is clear that,
based upon their unique role in the criminal justice system, prosecutors generally are
bound by their assurances, particularly when defendants rely to their detriment upon
those guarantees.
word, to enforce promises, to ensure that defendants’ decisions are made with a full
understanding of the circumstances, and to prevent fraudulent inducements of waivers of
one or more constitutional rights. Prosecutors can be bound by their assurances or
decisions under principles of contract law or by application of the fundamental fairness
considerations that inform and undergird the due process of law. The law is clear that,
based upon their unique role in the criminal justice system, prosecutors generally are
bound by their assurances, particularly when defendants rely to their detriment upon
those guarantees.
22 Ultimately, the court did not grant the defendant relief under a theory of detrimental
reliance because there was “no claim in this case of such reliance.” Scotland, 614 F.2d
at 365.
reliance because there was “no claim in this case of such reliance.” Scotland, 614 F.2d
at 365.
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DOJ-OGR-00004870
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