United States v. Muratella, No. 16-1265 (8th Cir. 2016)
Annotate this CaseMuratella was charged with conspiracy to distribute methamphetamine, 21 U.S.C. 841(a)(1). The prosecution proposed a plea agreement without mentioning a 21 U.S.C. 851 information. The following morning, the prosecution stated that due to a policy change it likely would have to file a section 851 information alleging that Muratella had a prior felony drug conviction. If Muratella was found to have such a prior conviction, the statutory mandatory minimum sentence would increase from 10 to 20 years. The parties had numerous discussions, but could not reach an agreement. Two weeks before trial, the prosecution inquired whether Muratella changed his position and stated that, if not, it would file the section 851 information. The next day, Muratella moved for a change of plea hearing, which was set for September 18. On September 17, the government filed the information. At the hearing, the court informed Muratella that he faced a mandatory minimum sentence of 20 years. Muratella said that he understood and entered an unconditional guilty plea. Before sentencing, Muratella objected to the filing of the section 851 information on grounds that his prior conviction was too old to qualify and that the filing violated Department of Justice policy. After reviewing the evidence, the court found that the government had made its intentions to file the 851 information known months earlier and that no vindictive prosecution occurred. The Eighth Circuit affirmed, finding that claim foreclosed by Muratella’s unconditional plea.
Court Description: Gruender, Author, with Beam and Colloton, Circuit Judges] Criminal case - Criminal law. Defendant pleaded guilty to the underlying offense after the Government filed the Section 851 information, and his guilty plea waived his claim that the filing of the information amounted to vindictive prosecution.
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