Academic journal article Journal of Criminal Law and Criminology

When Rules Are More Important Than Justice

Academic journal article Journal of Criminal Law and Criminology

When Rules Are More Important Than Justice

Article excerpt

Carlisle v. United States, 116 S. Ct. 1460 (1996)

I. INTRODUCTION

In Carlisle v. United States,(1) the United States Supreme Court held that a federal district court lacked the authority to grant a motion for judgment of acquittal filed one day after the expiration of the time period prescribed by Federal Rule of Criminal Procedure 29(c). Rule 29(c) requires that when a jury has returned a guilty verdict, motions for judgment of acquittal must be filed within seven clays of the jury's discharge.(2) The Supreme Court found that the Federal Rules of Criminal Procedure (the "Rules") prohibit a trial court from granting an untimely motion for judgment of acquittal.(3) In addition, the Court found that a district court does not possess an inherent supervisory power that would allow it to enter a post-verdict judgment of acquittal sua sponte.(4)

This note argues that the Supreme Court correctly found that the Federal Rules of Criminal Procedure do not permit the granting of an untimely post-verdict motion for judgment of acquittal. Rule 29(c), when read in conjunction with Rule 45(b), prohibits a trial court from granting a motion for judgment of acquittal filed after the expiration of the seven-day time period included in Rule 29(c), unless the court has extended the time limit during the seven days. However, this note also argues that the Supreme Court erred when it rejected the existence of an inherent supervisory power as an alternative authority for the trial court's action. The Court justified its decision by noting the absence of any long, unquestioned power of federal district courts to acquit for insufficient evidence sua sponte after return of a guilty verdict. However, there is a tradition of entrusting lower courts with the responsibility of ensuring justice and protecting innocent criminal defendants from wrongful convictions. The Court's refusal to acknowledge this tradition of supervisory power led to the incarceration of a man whom the trial judge believed was innocent.

II. BACKGROUND

A. RULE 2 AS A GUIDE TO INTERPRETATION OF THE FEDERAL RULES OF CRIMINAL PROCEDURE

The Federal Rules of Criminal Procedure became effective on March 21, 1946.(5) Federal Rule of Criminal Procedure 2 explains the purpose of the Rules.(6) The Rules were adopted for three main reasons. The first reason for the adoption of the Rules is to "secure simplicity in procedure."(7) The courts have reached the goal of simplifying procedure by finding that the Rules were designed to abolish the technicalities which led to the dismissal of cases or the reversal of convictions for reasons unconnected with the guilt or innocence of the defendant.(8) The second reason for the promulgation of the Federal Rules is to ensure "fairness in administration."(9) This purpose of the Rules has been cited to justify the establishment of uniform procedures among the district courts to ensure the equal treatment of every defendant.(10) The final reason given for the adoption of the Rules is to eliminate "unjustifiable expense and delay."(11) The Supreme Court has accepted this purpose of the Rules as expressed in Rule 2. In Bruton v. United States,(12) the Supreme Court opined that the Rules are intended to promote economy and efficiency so long as the rights of the defendant are not compromised.(13) In interpreting Rule 2, the Supreme Court also said that the Rules "were designed to eliminate technicalities in criminal pleading and are to be construed to secure simplicity in procedure."(14) In Fallen v. United States,(15) the Court stated that Rule 2 makes clear that the Criminal Rules "are not, and were not intended to be, a rigid code to have an inflexible meaning irrespective of the circumstances."(16)

B. FEDERAL RULE OF CRIMINAL PROCEDURE 29

When promulgated, Rule 29(a) abolished the common law motion for a directed verdict and replaced it with the motion for judgment of acquittal. …

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