Buford v. United States
Encyclopedia
Buford v. United States, 532 U.S. 59 (2001), was a United States Supreme Court
case decided in 2001. The case concerned whether federal appellate courts should give deferential or de novo
review of certain Sentencing Guideline determinations made by a trial judge.
delievered the unanimous Opinion of the Court. He began by stating that the question in the case is "a narrow one" that is simply based on the standard of review
for appellate courts when reviewing this specific technical determination made by District Courts. Although it was a simple issue, seven circuit courts of appeal had differed on the standard to take. Breyer, turning to the actual question of the standard of review, argued for a deferential framing. "The district court", he wrote, "is in a better position than the appellate court to decide whether a particular set of individual circumstances demonstrates 'functional consolidation'". Because the Seventh Circuit had given deference instead of de novo (completely new) review of the lower court's determinations, the decision was affirmed. Buford's sentence remained the same.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case decided in 2001. The case concerned whether federal appellate courts should give deferential or de novo
De novo
In general usage, de novo is a Latin expression meaning "from the beginning," "afresh," "anew," "beginning again." It is used in:* De novo transcriptome assembly, the method of creating a transcriptome without a reference genome...
review of certain Sentencing Guideline determinations made by a trial judge.
Background
The United States Sentencing Guidelines are the series of rules which guide a federal trial judge in issuing a sentence to a convicted individual. In Buford, the trial judge had to determine whether certain prior convictions relating to drug-crime arrests should be considered 'related' or 'consolidated'. The judge ruled they should not (and thus count as five individual priors) and the Seventh Circuit Court of Appeals affirmed. The appellate court did not re-review the facts (de novo review), instead only reviewing certain legal aspects of the determination. Buford appealed to the U.S. Supreme Court on the grounds that the appellate court should have re-reviewed the determinations of the trial judge rather than defer to him.Opinion of the Court
Justice BreyerStephen Breyer
Stephen Gerald Breyer is an Associate Justice of the U.S. Supreme Court. Appointed by President Bill Clinton in 1994, and known for his pragmatic approach to constitutional law, Breyer is generally associated with the more liberal side of the Court....
delievered the unanimous Opinion of the Court. He began by stating that the question in the case is "a narrow one" that is simply based on the standard of review
Standard of review
In LAW, the standard of review is the amount of deference given by one court in reviewing a decision of a lower court or tribunal. A low standard of review means that the decision under review will be varied or overturned if the reviewing court considers there is any error at all in the lower...
for appellate courts when reviewing this specific technical determination made by District Courts. Although it was a simple issue, seven circuit courts of appeal had differed on the standard to take. Breyer, turning to the actual question of the standard of review, argued for a deferential framing. "The district court", he wrote, "is in a better position than the appellate court to decide whether a particular set of individual circumstances demonstrates 'functional consolidation'". Because the Seventh Circuit had given deference instead of de novo (completely new) review of the lower court's determinations, the decision was affirmed. Buford's sentence remained the same.