Eliezer Alberto Jimenez v. United States
This case presents a recurring constitutional question of exceptional importance. The Court has said in a variety of contexts that "the government may not deny a benefit to a person because he exercises a constitutional right." Koontz v. St. Johns River Water Mgmt. Dist., 570 U.S. 595, 604-605 (2013). Those cases "reflect an overarching principle, known as the unconstitutional conditions doctrine, that vindicates the Constitution's enumerated rights by preventing the government from coercing people into giving them up." Jd. Among the most important rights secured by the Constitution is "[t]he Privilege of the Writ of Habeas Corpus," U.S. Const., Art. I, § 9, cl. 2, a right guaranteed "even where the prisoner is detained after a criminal trial conducted in full accordance with the protections of the Bill of Rights," Boumediene v. Bush, 553 U.S. 723, 785 (2008). Notwithstanding the significance of an accused's decision to waive the right to habeas corpus (or its adequate substitute)—often the only available means of challenging the legality of a guilty plea, conviction, or sentence—this Court has never addressed whether conditioning a guilty plea on the waiver of the right to seek such postconviction relief violates the unconstitutional conditions doctrine.
The questions presented are:
1. Whether requiring a criminal defendant to waive the right to seek habeas corpus or its substitute as a condition of a guilty plea violates the unconstitutional conditions doctrine.
2. Whether a waiver of the right to seek habeas corpus or its substitute is unenforceable where, as here, its enforcement works a miscarriage of justice.
Whether requiring a criminal defendant to waive the right to seek habeas corpus or its substitute as a condition of a guilty plea violates the unconstitutional conditions doctrine