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

In an ideal world, a trial would never be unreasonably delayed or cut short. Judges would never need to juggle multiple difficult trials or drown in administrative tasks that distract from the fair adjudication of cases, and lawyers and litigants could be reassured that each judgment was arrived at fairly and after proper reflection. Congress created the magistrate system in an attempt to move the federal judiciary closer to this ideal state of affairs.\u27 The purpose of this Article I judicial system is to facilitate the resolution of less significant disputes and speed the administration of procedural tasks. When district judges can delegate discovery duties, pretrial matters, or petty disputes to magistrate judges, they should have more time to spend on more serious matters. Practically, this creates greater judicial efficiency by easing the workload for overburdened district courts and enabling the adjudication of a greater number of disputes. However, whether the magistrate system and its administrative benefits always help to achieve an optimally fair legal system remains unclear. This Note argues that the delegation to magistrate judges of felony-guilty-plea proceedings, though beneficial to district judges, raises concerns of fairness and constitutionality for criminal defendants. Accordingly, a magistrate judge should never accept such a plea. With the consent of litigants, magistrate judges presently have the authority to conduct misdemeanor trials and any or all proceedings in a jury or non-jury civil trial. However, although the Federal Magistrates Act is silent on the matter, the Supreme Court has indicated that magistrate judges lack the power to conduct felony trials. This places the authority to accept a felony guilty plea in a disputed area: functionally similar to duties like evidentiary hearings or misdemeanor trials, which magistrate judges commonly perform, but closer in significance to tasks they are not permitted to undertake, such as a felony trial. Courts have handled this problem in a few different ways, although none have entirely prohibited the delegation of all duties related to plea acceptance