Facts
- Federal prosecutors charged a construction company and its president with bid-rigging in violation of § 1 of the Sherman Act.
- Respondents were indicted in two separate conspiracy indictments, each tied to a different highway construction project and agreement to rig bids.
- In a single district-court proceeding, respondents, represented by counsel, pleaded guilty to both indictments.
- The district court accepted the pleas as voluntary and knowing, entered convictions, and imposed sentences.
- Afterward, respondents sought post-conviction relief under Fed. R. Crim. P. 35(a) and 28 U.S.C. § 2255 to vacate the second conviction, asserting the two indictments actually involved one conspiracy and thus violated the Double Jeopardy Clause.
- The district court initially denied relief; the court of appeals allowed extra-record evidence, leading the district court on remand to find a single conspiracy and vacate the second conviction; the court of appeals affirmed.
Issues
- Whether defendants who entered counseled, voluntary guilty pleas to two conspiracy indictments may later collaterally attack one conviction on double jeopardy grounds by introducing evidence outside the record to show the charges were really one conspiracy.
- Whether a guilty plea admits only the historical acts alleged or admits legal guilt of the charged offenses as framed by the indictments.
Decision
- The Supreme Court reversed and reinstated the second conviction and sentence.
- By pleading guilty to indictments that, on their face, alleged two distinct conspiracies, respondents admitted guilt to two separate offenses.
- Respondents could not contradict the admissions inherent in their pleas by relying on evidence outside the indictments and plea record.
- Any exception allowing a post-plea double jeopardy claim applies only when the double jeopardy defect is apparent from the face of the existing record; that condition was not met.
- The fact that respondents and counsel did not consider or discuss double jeopardy before pleading did not, by itself, avoid waiver flowing from a counseled, voluntary plea.
Legal Principles
- A counseled, voluntary guilty plea admits legal guilt of the substantive offense charged and generally forecloses collateral challenges based on non-jurisdictional defects.
- A guilty plea may not be used as a platform for later factual litigation that would contradict the indictments’ charges and the plea’s admissions.
- A double jeopardy claim can survive a guilty plea only when the claim is established by the face of the indictments and the existing record, such that the court lacked power to enter the conviction.
- When separate indictments facially charge distinct conspiratorial agreements, guilty pleas to both concede separateness for purposes of collateral review.
Conclusion
A voluntary, counseled guilty plea to two indictments that facially allege distinct conspiracies bars a later collateral double jeopardy attack that depends on evidence outside the plea record to recharacterize the offenses as one.