United States v. Valenzuela-Bernal
United States Supreme Court
458 U.S. 858 (1982)
- Written by Rich Walter, JD
Facts
Ricardo Valenzuela-Bernal (Bernal) (defendant) was arrested for the federal crime of transporting two illegal aliens. A federal prosecutor released the aliens for immediate deportation, after interviewing the aliens and determining that their testimony could not materially benefit either Bernal’s prosecution or his defense. At trial in federal district court, Bernal protested that he himself had been given no opportunity to interview the two deportees, though Bernal could not say what prejudicial effect that had on his case. Bernal was found guilty. On appeal, the Ninth Circuit reversed. The appellate court held that the deportation of an alien witness whose testimony might conceivably benefit a criminal defendant, before defense counsel has an opportunity to interview that witness, violates a defendant’s Fifth Amendment right to due process and Sixth Amendment right to compulsory process. The court further held that the conceivable-benefit test is satisfied if the deportee was an eyewitness to and active participant in the defendant’s alleged crime. The government appealed to the United States Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Rehnquist, J.)
Concurrence (O’Connor, J.)
Concurrence (Blackmun, J.)
Dissent (Brennan, J.)
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