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United States v. Hodge

United States Court of Appeals for the Third Circuit

412 F.3d 479 (2005)

Relevant factsFree

Devin Hodge (defendant) and his brother Irvine were indicted together for murder, and the prosecution offered them identical plea agreements, each contingent on the other brother also accepting. Both brothers pleaded guilty under this package deal and each received a life sentence, but the district court was never told the pleas were contingent on each other. Devin appealed, arguing the plea colloquy was improper because the court did not know his plea depended on his brother's.

IssueFree

Whether a district court commits reversible error in a package-deal guilty plea by failing to conduct a heightened plea colloquy when the prosecution never disclosed that the co-defendants' pleas were contingent on each other.

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