United States v. Laney, No. 15-10563 (9th Cir. 2018)
Annotate this CaseA presumption of validity did not attach to a stipulation by defense counsel that their clients waived their right to a jury trial on their criminal charges. The Ninth Circuit reversed based on the ineffective jury trial waivers in this case and held that the record was insufficient to show that the jury trial waivers were voluntary, knowing, and intelligent. The panel reasoned that the proper practice under Federal Rule of Criminal Procedure 23(a) was for the defendant to personally execute the written waiver. Therefore, the panel concluded that the convictions were supported by sufficient evidence, but remanded based on the ineffective jury trial waivers.
Court Description: Criminal Law The panel reversed the defendants’ convictions, and remanded, in a case in which defense counsel stipulated that their clients waived their right to a jury trial. The panel concluded that the convictions are supported by sufficient evidence, but that the jury-trial waivers were ineffective. The panel held that the proper practice under Fed. R. Crim. P. 23(a) is for the defendant to personally execute the written waiver; a written stipulation signed by defense counsel alone—like the stipulations at issue in this case— will not raise a presumption of validity. The panel explained that the absence of a defendant’s signature will not constitute reversible error if the record otherwise shows that the defendant’s waiver was voluntary, knowing, and intelligent. The panel could not determine from the record whether the defendant’s waivers were voluntary, knowing, and intelligent. The panel wrote that the stipulation here was tantamount to an oral waiver by counsel outside the
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