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The United States v. Christopher Lee Armstrong et al., 1995, was a case that revolved around the issue of racial discrimination in prosecutorial decision-making. Armstrong and his co-defendants were charged with federal drug offenses but sought to dismiss their indictments on grounds of selective prosecution based on race. They requested discovery for evidence supporting this claim, which the district court granted despite government objections. The U.S Government appealed this decision and the Supreme Court ruled in favor of it by reversing the lower court's order granting discovery. The Supreme Court held that defendants must meet a high threshold to justify discovery on claims of selective prosecution: they must present credible evidence showing both discriminatory effect (that similarly situated individuals of a different race were not prosecuted) and discriminatory intent (the decision to prosecute was motivated by race). In this case, Armstrong failed to provide specific evidence demonstrating that non-black defendants could have been prosecuted for similar crimes but weren't due to their racial identity; hence he did not meet these requirements.
In the dissenting opinion for United States v. Christopher Lee Armstrong et al., Justice Stevens, joined by Justices Ginsburg and Breyer, argued that the majority's decision to deny defendants' discovery request was a mistake. They contended that racial bias in prosecutorial decisions is an issue of grave concern and should be addressed rather than dismissed outright without investigation. The dissenters believed that if there were evidence suggesting discriminatory intent in prosecution, it would violate the equal protection component of the Fifth Amendment’s Due Process Clause. Therefore, they felt defendants should have been allowed access to government records which could potentially prove such discrimination existed within this case or more broadly within drug prosecutions as a whole.