United States v. Goodwin
Citation and Court
457 U.S. 368 (1982), Supreme Court of the United States
Facts
Goodwin was charged with misdemeanor offenses arising from an altercation with a federal officer. After he requested a jury trial, the prosecutor obtained a felony indictment for the same conduct. Goodwin was convicted of the felony and argued that the upgraded charge was presumptively vindictive under Blackledge v. Perry.
Issue
Whether a presumption of prosecutorial vindictiveness applies when a prosecutor brings more serious charges after a defendant exercises the right to a jury trial in the pre-trial context.
Holding
A presumption of prosecutorial vindictiveness does not arise from a pre-trial charging decision made after a defendant exercises his right to a jury trial; the presumption from Blackledge applies only in the post-conviction context.
Rule / Doctrine
The presumption of vindictiveness is context-sensitive. In the post-trial/post-conviction context (Blackledge), the risk of retaliation is high and the presumption applies. In the pre-trial context, a prosecutor’s decision to bring additional charges may reflect legitimate re-evaluation of the case rather than retaliation, so no presumption arises — the defendant must prove actual vindictiveness.
Significance
Goodwin limits Blackledge v. Perry and clarifies when the vindictiveness presumption applies. The distinction between pre-trial charging decisions and post-conviction upgrades is central to understanding the doctrine and is heavily tested in criminal procedure courses.