United States v. Dominguez Benitez

United States v. Dominguez Benitez
Supreme Court of the United States
Argued April 21, 2004 Decided June 14, 2004
Full case name	United States, Petitioner v. Carlos Dominguez Benitez
Citations	542 U.S. 74 (more) 124 S. Ct. 2333; 159 L. Ed. 2d 157; 2004 U.S. LEXIS 4177; 72 U.S.L.W. 4478; 17 Fla. L. Weekly Fed. S 379
Argument	Oral argument
Case history
Prior	Defendant convicted, C.D. Cal., affirmed in part, reversed and remanded, 30 Fed. Appx. 706 (9th Cir. Jan 29, 2002); reversed and remanded, 310 F.3d 1221 (9th Cir. 2002); separate ruling denying substitution of counsel affirmed, 2002 U.S. App. LEXIS 24416 (9th Cir. 2002); cert. granted, 540 U.S. 1072 (2003)
Subsequent	On remand, conviction affirmed, 381 F.3d 859 (9th Cir. 2004)
Holding
An untimely objection to the omission of a Rule 11 warning warrants reversal only if there is a reasonable probability that but for the trial court's error, the defendant would not have pleaded guilty. The reversal of a conviction for a Rule 11 violation without requiring the defendant to show prejudice was accordingly improper. Ninth Circuit Court of Appeals reversed and remanded.
Court membership
Chief Justice William Rehnquist Associate Justices John P. Stevens · Sandra Day O'Connor Antonin Scalia · Anthony Kennedy David Souter · Clarence Thomas Ruth Bader Ginsburg · Stephen Breyer
Case opinions
Majority	Souter, joined by Rehnquist, Stevens, O'Connor, Kennedy, Thomas, Ginsburg, Breyer
Concurrence	Scalia
Laws applied
Fed. R. Crim. P. 11; 52

United States v. Dominguez Benitez, 542 U.S. 74 (2004), was a United States Supreme Court case in which the Court ruled that, in a criminal proceeding in federal court, a defendant who does not alert the district court to a possible violation of Rule 11 of the Federal Rules of Criminal Procedure must show on appeal that the violation affirmatively affected his rights in order to obtain reversal of his conviction by guilty plea. Rule 11, which pertains to criminal prosecutions in United States federal courts only, governs the offering of plea bargains to criminal defendants and the procedures district courts must employ to ensure that the defendant knows of and properly waives his trial-related constitutional rights.

In Benitez, the trial court violated Rule 11 when it took the defendant's plea by failing to warn him that the plea could not be withdrawn if the court did not accept the prosecution's sentencing recommendations. The United States Court of Appeals for the Ninth Circuit reversed the conviction, considering that the non-English speaking defendant did not understand his rights under those circumstances.

The Supreme Court unanimously reversed, ruling the Court of Appeals had applied the wrong test by not requiring the defendant to show how the error actually prejudiced the proceedings. The Court of Appeals had consequently failed to consider the entire record regarding what the defendant understood. An eight-justice majority of the Supreme Court, in an opinion by Justice David Souter, held that a defendant attempting to reverse his conviction due to a Rule 11 violation must show a reasonable probability that, but for the trial court's error, he would not have entered the plea. Justice Antonin Scalia concurred in the judgment but disagreed with the majority's standard.