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Menna v. New York

• 1975 • 423 U.S. 61 • Burger Court
In Menna v. New York, the defendant, Frank Menna, pleaded guilty to a charge of second-degree forgery in 1971. However, he later argued that his prosecution was in violation of the Fifth Amendment's double jeopardy clause because he had already been convicted and sentenced for the same offense under federal law. The Supreme Court ruled in favor of Menna stating that since his claim did not challenge the factual basis of his conviction but rather its constitutionality due to double jeopardy...Open Case
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Chief Burger Court
Term: 1975
Docket: 75-5401
423 U.S. 61
96 S. Ct. 241
46 L. Ed. 2d 195
1975 U.S. LEXIS 96

Menna v. New York

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Opinion Summary
AI Abstract

In Menna v. New York, the defendant, Frank Menna, pleaded guilty to a charge of second-degree forgery in 1971. However, he later argued that his prosecution was in violation of the Fifth Amendment's double jeopardy clause because he had already been convicted and sentenced for the same offense under federal law. The Supreme Court ruled in favor of Menna stating that since his claim did not challenge the factual basis of his conviction but rather its constitutionality due to double jeopardy concerns, it could be raised even after a voluntary guilty plea. Therefore, despite pleading guilty initially which usually waives all non-jurisdictional defects in criminal proceedings including constitutional violations; if such plea is compelled by threats or promises (coerced), it can still be challenged on grounds like double jeopardy as per this ruling.

Dissent Summary
AI Abstract

In the dissenting opinion for Menna v. New York, Justice Rehnquist argued that the majority's decision was inconsistent with previous rulings of the Court and could potentially undermine public respect for courts and their judgments. He contended that Menna had waived his right to claim double jeopardy by pleading guilty, as he did not raise this issue at trial or on appeal in state court. Furthermore, he believed that a plea of guilty should be considered an admission of guilt which waives all non-jurisdictional defects in a criminal proceeding. Therefore, according to him, it is inappropriate for federal courts to intervene after such a plea has been entered unless there are exceptional circumstances - something which he didn't believe existed in this case.

Opinion written by Justice
Decided: Nov 17, 1975
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