USA v. Raymon Walters
Split Score
What is a Split Score?
This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Affirmed
The Third Circuit affirmed Raymon Walters’s conviction for being a felon in possession of a firearm. It held that, under the Sixth Amendment, a defendant—not counsel—controls the decision to concede or stipulate to substantive elements of the charged offense, so the district court properly rejected counsel’s attempt to enter a stipulation over Walters’s objection and admitted evidence of his prior convictions. The court also concluded that 18 U.S.C. § 922(g)(1) is not plainly unconstitutional as applied to Walters under recent Second-Amendment precedent.
Circuit Split Identified
Legal Issue
Whether the Sixth Amendment gives the defendant (rather than counsel) ultimate authority to decide whether to concede or stipulate to individual substantive elements of the charged offense.
Circuit Positions
Defendant has ultimate authority; counsel may NOT stipulate to substantive elements over the defendant’s objection.
Counsel may stipulate to individual elements even over the defendant’s objection; McCoy is limited to concessions of the entire charged crime.
Conflict Summary
The Third Circuit holds that a defendant alone may decide whether to concede discrete substantive elements (such as felon status and knowledge) and counsel may not enter such a stipulation over the defendant’s objection. The Second Circuit, by contrast, has ruled that counsel can unilaterally stipulate to individual elements despite the defendant’s objection because McCoy v. Louisiana concerns only concessions of the entire offense, not individual elements.