Ricketts v. Adamson, 483 U.S. 1 (1987)

At the beginning of his trial for first-degree murder, Adamson and the prosecutor reached a plea agreement whereby he would plead guilty to second-degree murder and testify against others involved in the murder. Adamson understood that if he refused to testify the original charge would be automatically reinstated. Adamson testified and his accomplices were convicted of first-degree murder. The Arizona Supreme Court threw out their convictions, however, and ordered a new trial. Adamson believed his obligation to testify terminated when he was sentenced and refused to testify at the second trial.

The trial court did not compel him to testify and the government filed new information reinstating the initial charge of first-degree murder. He tried to quash the information on double jeopardy grounds. Adamson then offered to testify at his accomplices’ retrial, but this offerwas denied and hewas convicted of first-degree murder and sentenced to death. Adamson sought federal habeas relief, asserting that the reinstatement of first-degree murder charges after his conviction on second- degree murder was a violation of double jeopardy.

The U.S. Supreme Court reversed and held that Adamson’s prosecution for first-degree murder did not violate double jeopardy principles, since his breach of the plea agreement removed the double jeopardy bar that otherwise would prevail.

MARILYN MCAULEY

Cases and Statutes Cited

• Blackledge v. Allison, 431 U.S. 63, 75 (1977)
• Boykin v. Alabama, 395 U.S. 238, 242 (1969)
• United States v. Scott, 437 U.S. 82 (1978)

See also Double Jeopardy: Modern History; Guilty Plea; Plea Bargaining