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Efficiency Run Amok: Challenging the Authority of Magistrate Judges to Hear and Accept Felony Guilty Pleas

Posted by on Monday, November 23, 2015 in Notes, Volume 68, Volume 68, Number 6.

Efficiency Run Amok: Challenging the Authority of Magistrate Judges to Hear and Accept Felony Guilty Pleas


Since the passage of the Federal Magistrates Act in 1968, district judges with overloaded dockets have been able to delegate many of their most time-consuming duties to magistrate judges. In theory, this system allows district judges to spend less time on administrative or “subsidiary” tasks and more time in an “adjudicatory” function. But certain tasks, no matter how tedious, may be too important for the Article III judiciary to assign to Article I officers. This Note analyzes a circuit split that has recently emerged over whether district judges may delegate to magistrate judges the acceptance of a guilty plea in a felony case. Although a guilty-plea proceeding is similar in many ways to tasks that magistrate judges commonly undertake, it implicates rights of greater importance than those analogous duties. The significance of these rights is a factor in determining whether magistrate judges have the statutory authority to perform such a duty. Furthermore, it raises separation-of-powers concerns that highlight constitutional issues with current Federal Magistrates Act jurisprudence. These analyses are only further complicated by the unique ancillary consequences of felony-guilty-plea acceptance, including effects on plea withdrawal and immediate detention of criminal defendants. After examining these issues, this Note proposes a system by which magistrate judges can preside over plea proceedings on a condition of non-finality, bolstering judicial efficiency without raising concerns of constitutionality or fairness to defendants.


J.D. Candidate, May 2016, Vanderbilt University Law School; B.A., 2010, Northwestern University. I would like to thank the staff of the Vanderbilt Law Review for their hard work on this note. This has been a maddening, wonderful, and unforgettable experience. More than anything, I am indebted to the daily love, support, and patient listening of Kate Dutcher and Dana Mendel. I dedicate this note to my father, who I wish could have read it. All remaining errors and gaps in logic are my own.