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United States v. Bailey

United States Supreme Court

444 U.S. 394 (1980)

Relevant factsFree

Bailey and several co-defendants escaped from a federal detention facility by climbing through a window and sliding down a knotted bedsheet, and after recapture were convicted of escape under 18 U.S.C. § 751(a); at trial, the defendants sought to present duress or prison-conditions defenses (rejected for lack of evidence they tried to surrender once free from the alleged conditions), and the court of appeals reversed, holding the government also had to prove the defendants acted with a specific intent to avoid confinement, distinguishing that from merely fleeing intolerable non-confinement conditions.

IssueFree

Whether a defendant may be convicted under the federal escape statute, 18 U.S.C. § 751(a), based on knowledge that he was leaving custody without authorization.

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