United States V. Dominguez Benitez

United States v. Dominguez Benitez, 542 U.S. 74 (2004), was a United States Supreme Court case in which the Court ruled that, in a criminal proceeding in federal court, a defendant who does not alert the district court to a possible violation of Rule 11 of the Federal Rules of Criminal Procedure must show on appeal that the violation affirmatively affected his rights in order to obtain reversal of his conviction by guilty plea. Rule 11, which pertains to criminal prosecutions in United States federal courts only, governs the offering of plea bargains to criminal defendants and the procedures district courts must employ to ensure that the defendant knows of and properly waives his trial-related constitutional rights.

In Benitez, the trial court violated Rule 11 when it took the defendant's plea by failing to warn him that the plea could not be withdrawn if the court did not accept the prosecution's sentencing recommendations. The United States Court of Appeals for the Ninth Circuit reversed the conviction, considering that the non-English speaking defendant did not understand his rights under those circumstances.

The Supreme Court unanimously reversed, ruling the Court of Appeals had applied the wrong test by not requiring the defendant to show how the error actually prejudiced the proceedings. The Court of Appeals had consequently failed to consider the entire record regarding what the defendant understood. An eight-justice majority of the Supreme Court, in an opinion by Justice David Souter, held that a defendant attempting to reverse his conviction due to a Rule 11 violation must show a reasonable probability that, but for the trial court's error, he would not have entered the plea. Justice Antonin Scalia concurred in the judgment but disagreed with the majority's standard.