Puckett v. United States

Puckett v. United States
Supreme Court of the United States
Decided March 25, 2009
Full case name	Puckett v. United States
Citations	556 U.S. 129 ( more )
Holding
Rule 52(b)'s plain error test applies to challenges of whether the prosecutor failed to follow through on a plea bargain, so those challenges generally cannot be made for the first time on appeal.
Court membership
Chief Justice John Roberts Associate Justices John P. Stevens  · Antonin Scalia Anthony Kennedy  · David Souter Clarence Thomas  · Ruth Bader Ginsburg Stephen Breyer  · Samuel Alito
Case opinions
Majority	Scalia
Dissent	Souter, joined by Stevens
Laws applied
Federal Rules of Criminal Procedure

Puckett v. United States, 556 U.S. 129(2009), was a United States Supreme Court case in which the court held that Rule 52(b)'s plain error test applies to challenges of whether the prosecutor failed to follow through on a plea bargain, so those challenges generally cannot be made for the first time on appeal. ^{[1] [2]}

Background

In exchange for petitioner Puckett's guilty plea, the prosecution agreed to request (1) a three-level reduction in his offense level under the Federal Sentencing Guidelines on the ground that he had accepted responsibility for his crimes; and (2) a sentence at the low end of the applicable Guidelines range. The federal District Court accepted the plea. ^[1]

However, before Puckett was sentenced, he assisted in another crime. As a result, the prosecution opposed any reduction in Puckett's offense level, and the District Court denied the three-level reduction. On appeal, Puckett raised for the first time the argument that by backing away from its reduction request, the Government had broken the plea agreement. ^[1]

The Fifth Circuit Court of Appeals found that Puckett had forfeited that claim by failing to raise it below; applied Federal Rule of Criminal Procedure Rule 52(b)'s plain-error standard for unpreserved claims of error; and held that, although the error had occurred and was obvious, Puckett had not satisfied the third prong of plain-error analysis in that he failed to demonstrate that his ultimate sentence was affected, especially since the District Judge had found that acceptance-of-responsibility reductions for defendants who continued to engage in criminal activity were so rare as "to be unknown." ^[1]

Opinion of the court

The Supreme Court issued an opinion on March 25, 2009. ^[1]

References

1. Puckett v. United States, 556 U.S. 129 (2009).
2. Denniston, Lyle (March 25, 2009). "Clarity on broken plea bargains". SCOTUSblog. Retrieved September 2, 2025.

External links

• Text of Puckett v. United States, 556 U.S. 129(2009) is available from: Cornell Findlaw Justia

This article incorporates written opinion of a United States federal court. As a work of the U.S. federal government, the text is in the public domain .