In the case of United States v. Anthony Davila, the Supreme Court ruled that a federal judge's participation in plea negotiations, which is prohibited under Rule 11(c)(1) of the Federal Rules of Criminal Procedure, does not automatically require reversal of a defendant’s guilty plea. The court held that such error can be harmless if it did not affect "the framework within which the trial proceeds," or was not "structural." In this case, Anthony Davila had been charged with conspiracy to defraud and pleaded guilty after being advised by a magistrate judge to work out an agreement with prosecutors. He later appealed his conviction on grounds that he felt pressured into accepting a deal due to judicial involvement in his plea discussions. However, since there were no clear indications that Davila would have proceeded differently without these comments from the judge during pretrial proceedings (i.e., gone to trial instead), it was concluded by majority opinion written by Justice Ruth Bader Ginsburg that any violation could be considered harmless error.

In the dissenting opinion for United States v. Anthony Davila, Justice Sotomayor argued that the majority's decision was too broad and could potentially undermine Rule 11 of Federal Rules of Criminal Procedure. She contended that while it is important to ensure defendants are not coerced into pleading guilty, there should be a balance between protecting defendant rights and maintaining judicial efficiency. The justice believed that remanding every case back to district courts whenever a judge participated in plea discussions would unnecessarily burden lower courts with retrials or re-sentencing hearings. Instead, she suggested an approach where harmless errors by judges during plea negotiations do not automatically invalidate pleas but rather are evaluated on a case-by-case basis considering whether such participation influenced the defendant’s decision to plead guilty.