Bousley v. United States

Summary

Chief Justice Rehnquist's majority opinion held that Bousley could invoke Bailey's interpretation of the federal firearm statute to challenge the intelligence of his guilty plea on collateral review. Although his failure to challenge the plea on direct appeal procedurally defaulted that claim, and he could not establish cause, he could obtain merits review by demonstrating actual innocence. The Court reversed and remanded to permit that showing, allowing the Government to introduce admissible evidence beyond the plea record. Justice Stevens, concurring in part and dissenting in part without any joiners, agreed that collateral relief was available but would have directed that the conviction be vacated and Bousley permitted to plead anew, without requiring him to overcome procedural default. Justice Scalia, joined by Justice Thomas, dissented, arguing that the actual-innocence exception should not extend to convictions based on guilty pleas.