United States v. Bailey

Clifford Bailey, James T. Cogdell, Ronald C. Cooley, and Ralph Walker (collectively Defendants) were inmates at a federal detention facility located in Washington, D.C. Early one morning, the Defendants crawled through a window, slid down a knotted bed sheet, and escaped from custody. After varying periods of time, each Defendant was re-captured and charged with escape in violation of 18 U.S.C. 751(a). The Defendants were scheduled to be tried together but at the last minute, Cogdell secured a severance to be tried separately. At the trial of Bailey, Cooley, and Walker, each Defendant attempted to present evidence of duress as a defense, which was rejected by the court. Bailey, Cooley, and Walker were convicted. At Cogdell’s trial, he attempted to present evidence of deplorable conditions at the prison as a defense for his escape. The court rejected that defense argument as well and Cogdell was convicted. During both trials, the court stressed that to sustain the defenses, Defendants would have to introduce some evidence that they tried to surrender or engaged in similar conduct once they freed themselves from the conditions described. On appeal, the court of appeals for the District of Columbia narrowly reversed the convictions and held that the trial court had improperly excluded evidence offered by each defendant. The U.S. Supreme Court granted certiorari to review.