Gonzalez v. United States, 553 U.S. 242 (2008)
Primary Holding
Petitioner’s counsel has the authority to consent to a magistrate judge presiding over voir dire and jury selection in a felony criminal trial, and the defendant's personal consent is not required.
In the case of Gonzalez v. United States, the Supreme Court decided that a lawyer can agree to have a magistrate judge handle jury selection in a serious criminal trial without needing the defendant's personal approval. This matters because it clarifies that defendants don't always have to be asked directly about such decisions, which can streamline the legal process. For consumers, this case is relevant if they or someone they know is facing criminal charges, as it helps define how their legal representation can make decisions on their behalf.
AI-generated plain-language summary to help you understand this case
In Gonzalez v. United States, 553 U.S. 242 (2008), Homero Gonzalez was charged with five felony drug offenses in the United States District Court for the Southern District of Texas. During the jury selection process, the presiding Magistrate Judge inquired whether the parties consented to her overseeing the voir dire and jury selection. Gonzalez's attorney responded affirmatively, but Gonzalez himself was not asked for his consent, nor was there any indication that he was aware of his right to consent or waive. The Magistrate Judge conducted the jury selection without any objections from Gonzalez or his counsel, and a District Judge later presided over the trial, resulting in a guilty verdict on all counts. After his conviction, Gonzalez appealed, raising the issue for the first time that his own consent to the Magistrate Judge's role in jury selection was necessary. The United States Court of Appeals for the Fifth Circuit affirmed his convictions, ruling that Gonzalez could not demonstrate that the error was plain and concluded that his counsel's consent was sufficient to waive the right to have an Article III judge preside over voir dire. The court noted a split among the circuit courts on this issue, with some requiring personal consent from the defendant and others allowing counsel to consent on behalf of the defendant. The Supreme Court granted certiorari to resolve this discrepancy. The case highlights the procedural complexities surrounding the role of magistrate judges in federal criminal proceedings, particularly regarding the consent required for them to preside over critical stages such as jury selection. The Federal Magistrates Act allows district courts to delegate certain functions to magistrate judges, but the question of whether a defendant's personal consent is necessary remains contentious, as evidenced by the differing interpretations among the circuit courts.
Whether a defendant's counsel alone can consent to a magistrate judge presiding over voir dire and jury selection in a felony criminal trial, or whether the defendant must provide personal consent.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- January 8, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Kennedy
- Damages Awarded
- N/A
- Data Quality
- high
United States v. Gonzalez-Lopez, 548 U.S. 140 (2006)
Consumer WonA criminal defendant has a constitutional right to the counsel of their choice, and an erroneous deprivation of that right requires reversal of a conviction.
Rothgery v. Gillespie County, 554 U.S. 191 (2008)
Consumer WonThe right to counsel guaranteed by the Sixth Amendment attaches at the first appearance before a judicial officer where a defendant is informed of the formal accusation against him, but it does not require that a public prosecutor be aware of or involved in that initial proceeding.
Gonzalez v. Crosby, 545 U.S. 524 (2005)
Consumer LostA motion for relief from a judgment in a habeas corpus case, filed under Federal Rule of Civil Procedure 60(b), is subject to the restrictions that apply to “second or successive” habeas corpus petitions under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).
Schriro v. Landrigan, 550 U.S. 465 (2007)
Consumer LostThe decision to grant an evidentiary hearing in federal habeas relief cases rests within the discretion of the district court, and such a hearing is not warranted if the applicant cannot make out a colorable claim of ineffective assistance of counsel.