United States v. Valenzuela-Bernal
Case Date: 05/05/1982
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United States v. Valenzuela-Bernal, 458 U.S. 858 (1982), is a case that determines the constitutionality of deporting aliens who might give testimony in criminal alien smuggling prosecutions. Because deporting alien witnesses might take away a testimony that would be both “material and favorable” to the defendant, it gives rise to a potential motion from the defense to dismiss the indictment under the Compulsory Process Clause of the Sixth amendment and the Due Process Clause of the Fifth Amendment. In United States v. Valenzuela-Bernal, the Supreme Court was faced with the issue that these clauses were violated because the aliens that were involved in the incident were deported though their testimony may have potentially helped the defendant. In order to prove their case, the defense had to show that the testimony of the deported witnessed may have been favorable to the defense in ways that the testimonies of the available witnesses were not. The Supreme Court ultimately decided that because the defendant failed to make a “plausible suggestion that the deported aliens possessed any material evidence that was not merely cumulative of other evidence,” the District Court properly denied the respondent’s motion to dismiss the indictment. This decision interprets the Sixth Amendment right to compulsory process in the context of an alien-smuggling prosecution.
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