Smith v. United States (2013)

Smith v. United States, 568 U.S. 106 (2013), was a case decided by the Supreme Court of the United States of America.[1] The case was argued on November 6, 2012 and decided on January 9th, 2013.[2]

Roberts Court
Smith v. United States
Argued November 6, 2012
Decided January 9, 2013
Full case nameSmith v. United States
Docket no.11-8976
Citations568 U.S. 106 (more)
133 S. Ct. 714; 184 L. Ed. 2d 570
ArgumentOral argument
Case history
Prior
  • Motion to sever for trial granted, United States v. Gray, 173 F. Supp. 2d 1 (D.D.C. 2001);
  • Order requiring defendants to wear stun belts during trial, United States v. Gray, 254 F. Supp. 2d 1 (D.D.C. 2002);
  • Defendants convicted, motion for new trial denied, United States v. Gray, 292 F. Supp. 2d 71 (D.D.C. 2003)
  • Affirmed sub nom., United States v. Moore, 651 F.3d 30 (D.C. Cir. 2011)
  • Cert. granted sub nom., Smith v. United States, 567 U.S. 916 (2012).
Holding
9-0 in favor of United States. The burden of proof remains on the defendant to prove withdrawal from a conspiracy.
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia · Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinion
MajorityWritten by Justice Scalia

Question of the Case

When a group has been charged with drug conspiracy, and several key members of the group claim they withdrew from the conspiracy at a point in time that would call into question the statute of limitations, is it the role of the government to prove that the drug conspiracy continued in a way that nullifies the statute of limitations? [1]

Facts of the case

There were six men, convicted through trial of several charges, including violations of the RICO act and drug conspiracy.[1] The specific statutes are 21 U.S.C. § 846 and 18 U.S.C. § 1962(d), where the prior regards attempt and conspiracy, and the latter regards prohibited activities.[2][3][4] The statute used in defense of Smith was 18 U.S.C. § 3282.[5] The case had been heard by the District of Columbia Circuit Court, which held that Smith should be convicted so long as the government had proven beyond a reasonable doubt the existence of conspiracy and Smith's involvement.[2] The court held that the jury should rule in favor of Smith if he proves that he withdrew from the conspiracy at a time appropriate to the statute of limitations, as the burden of proof was on Smith if the government proved his involvement in the conspiracy.[2]

Decision

In a unanimous decision, the court, with the majority opinion written by Antonin Scalia sided against Smith.[1] The court created a new precedent that presumes involvement in a conspiracy if the statute of limitations defense is used, shifting the burden of proof to the defendant.[2] The court determined that it is the burden of the defendant to prove that they withdrew from a conspiracy, and that they did so past the statute of limitations.[2] The Due Process Clause of The Constitution of the United States of America is not violated by putting the burden of proof on the defendant.[2] Though argued by the defendant, the court concluded that Mullaney v. Wilbur does not apply in this case.[6] Because Smith took part in a conspiracy, the defense of withdrawal is to be proven by the defendant, as it is assumed that he was a part of the conspiracy throughout.[6] The court also decided that innocence is not determined solely by withdrawing from a conspiracy, as withdrawal has to coincide with the statute of limitations.[2] To further understand the burden of proof on the government in accordance with the ruling, see Dixon v. United States.[7]

References
  1. "Oyez, Smith v. United States". www.oyez.org. Retrieved 2018-10-04.
  2. Smith v. United States, 568 U.S. 106 (2013).
  3. 21 U.S.C. § 846.
  4. 18 U.S.C. § 1962(d).
  5. 18 U.S.C. § 3282.
  6. "Opinion analysis: When a defense is just a defense - SCOTUSblog". SCOTUSblog. 2013-01-14. Retrieved 2018-11-29.
  7. Dixon v. United States, 548 U.S. 1 (2006).
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