Commonwealth V. Battis In The 1800's

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Plea Bargain Origins
In the early days of English common law, courts would hear several cases per day and make a decision. This decision would be made without having lawyers present. As time went on lawyers were added to trials and the process significantly slowed. Increases in criminal activity meant more and more cases to potentially go to trial. With trials continually adding up and no increase in prison facilities to house the guilty, courts had to decide whether to allow defendants to plead out their case in lieu of a trial. In the United States one of the earliest cases involving a plea was in that of Commonwealth v. Battis in the beginning of the 1800’s.
Early U.S. Plea Deals
In the case of Commonwealth v. Battis (1804) the court did not immediately agree with allowing the defendant to plea out his case. They went through a rigorous examination of everyone involved to discover the sanity of the prisoner and the behavior of all law enforcement officials. It was necessary to discover if the defendant had at all been coerced into agreeing to plead guilty to the charges with which he was faced. Late in the 19th century Alameda County in California began to see a rise in plea bargains following the case of Albert McKenzie. McKenzie was faced with felony charges for stealing around $50 from the company he worked for. Instead of going through the process of a trial he decided to plead guilty to a lesser charge. This case was at the beginning of a rise in plea bargains in that county.
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By the middle of the century, state commissions in several states were reporting continued increases in plea bargaining. Statistics in New York State showed a trend of guilty pleas in nearly all cases. The Georgia Department of Public Welfare showed an increase of more than half of all cases over a period of five years in the early