United States v. Mezzanatto
Citation: 513 U.S. 196 (1995) Court: Supreme Court of the United States
Facts
Gary Mezzanatto sought to negotiate a plea agreement with federal prosecutors. Before the proffer session began, prosecutors required him to sign a waiver agreeing that any statements he made during the proffer could be used to impeach him if he testified inconsistently at trial. The plea negotiations broke down. At trial, Mezzanatto testified in a manner inconsistent with his proffer statements, and the government used those statements to impeach him. Mezzanatto argued the use was barred by FRE 410 and Fed. R. Crim. P. 11(e)(6), which exclude statements made during plea negotiations.
Issue
Whether the defendant may waive the protections of FRE 410 that bar the use of plea and proffer statements, making those statements admissible for impeachment at trial.
Holding
The Supreme Court (7-2) held that the exclusionary protections of FRE 410 are waivable by the defendant, and that Mezzanatto’s signed waiver was valid. The waiver was entered knowingly and voluntarily, and the government’s conditioning of plea discussions on such a waiver is permissible.
Rule / Doctrine
The protections of FRE 410 (and the corresponding criminal rule) are presumptively waivable. Rights created for the benefit of a party may generally be waived by that party unless waiver is expressly prohibited or would violate public policy. There is no categorical prohibition on waiving FRE 410’s exclusionary rule. Waivers of trial-related rights are valid if made knowingly and voluntarily. The government may condition the commencement of plea negotiations on the defendant’s agreement to waive FRE 410 protections.
Significance
United States v. Mezzanatto has significant practical consequences for plea bargaining: it allows prosecutors to require waiver of FRE 410 as a condition of any proffer meeting, which is now standard practice in many federal districts. The case illustrates the Court’s general approach that codified evidentiary protections, absent express statutory prohibition, can be waived by the parties they are designed to protect. It is taught in both Evidence and Criminal Adjudications courses for its intersection of evidentiary rules and the plea negotiation process.