United States v. Frady

456 U.S. 152 (1982)

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United States v. Frady

United States Supreme Court
456 U.S. 152 (1982)

  • Written by Arlyn Katen, JD

Facts

In 1963, Joseph Frady (defendant) was convicted and sentenced to death for robbing and murdering Thomas Bennett in Washington, D.C. Frady presented an innocence defense at his federal trial, claiming that he was uninvolved in Bennett’s murder and that the real murderer slipped away while police arrested Frady. Eventually, Frady stopped disputing that he killed Bennett and conceded that the evidence against him was overwhelming. For years, Frady challenged his sentence on direct appeal and through collateral proceedings, and ultimately, the United States Court of Appeals for the District of Columbia Circuit (D.C. Circuit) set aside Frady’s death sentence and ruled that Frady’s sentences for robbery and murder must run concurrently rather than consecutively. Frady then filed a collateral motion to vacate his sentence pursuant to 28 U.S.C. § 2255, arguing for the first time that the federal trial court erred by improperly instructing the jury about the definition of malice. Frady’s attorney did not object to the jury instructions at trial. The district court denied Frady’s § 2255 motion, but the D.C. Circuit reversed, finding that the jury instruction was a plain error. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (O’Connor, J.)

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