Mistretta v. United States
Encyclopedia
Mistretta v. United States, 488 U.S. 361
(1989), is a case decided by the United States Supreme Court
.
, argued that the sentencing guidelines he was facing were unconstitutional due to a gross distribution of authority by Congress
resulting in a violation of the separation of powers. Mistretta plead guilty to conspiracy to sell cocaine after the District Court denied his motion in return for a removal of two other counts. He received an eighteen-month sentence. He filed a petition to the Eighth Circuit
, but along with him, the Circuit Court filed a petition for writ of certiorari
to the Supreme Court and received the writ.
Justice Blackmun
delivered the majority opinion. As society increases in complexity, Congress must delegate its job “under broad general directives”. The broad delegation “is sufficiently specific and detailed to meet constitutional requirements.”
Congress has three goals in mind (1) guarantee to uphold the Act passed (2) provide certainty and fairness (3) establish uniform criminal justice process.
Congress specified four purposes of sentencing. (1) Reflect seriousness of offense, (2) promote respect for the law, (3) provide just punishment, (4) afford adequate deterrence, and provide defendant with needed correctional treatment.
Congress set forth a guideline system to be personable for the specific case and placed 7 factors to consider when sentencing: grade of offense, aggravating circumstances, nature and degree of harm, community view, public concern, deterrent effect, current incidence.
Another 11 factors were established to summarize the defendant: age, education, vocational skills, mental and emotional condition, physical condition, previous employment, family ties and responsibilities, community ties, role in the offense, criminal history, and degree of dependence upon crime for livelihood. Congress prohibited the Commission from addressing race, sex, national origin, creed, and socioeconomic status.
Congress went into enumerated detail of the guidelines the Sentencing Commission more than an “intelligible principle”—-the requirement for delegation of power.
believed the sentencing commission to be an unconstitutional delegation of legislative power by Congress to another agency because the guidelines established by the Sentencing Commission have the force of law: a judge who disregards them will be reversed. Scalia noted that the guidelines were 'heavily laden (or ought to be) with value judgments and policy assessments' rather than merely technical, Scalia also disputed the assertion by majority that the sentencing commission was in the judicial branch rather than the legislative saying the commission "is not a court, does not exercise judicial power, and is not controlled by or accountable to members of the Judicial Branch,"
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1989), is a case decided by the United States Supreme Court
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...
.
Background
John Mistretta, who sold cocaineCocaine
Cocaine is a crystalline tropane alkaloid that is obtained from the leaves of the coca plant. The name comes from "coca" in addition to the alkaloid suffix -ine, forming cocaine. It is a stimulant of the central nervous system, an appetite suppressant, and a topical anesthetic...
, argued that the sentencing guidelines he was facing were unconstitutional due to a gross distribution of authority by Congress
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
resulting in a violation of the separation of powers. Mistretta plead guilty to conspiracy to sell cocaine after the District Court denied his motion in return for a removal of two other counts. He received an eighteen-month sentence. He filed a petition to the Eighth Circuit
United States Court of Appeals for the Eighth Circuit
The United States Court of Appeals for the Eighth Circuit is a federal court with appellate jurisdiction over the district courts in the following districts:* Eastern District of Arkansas* Western District of Arkansas...
, but along with him, the Circuit Court filed a petition for writ of certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
to the Supreme Court and received the writ.
Issues presented
Was the Sentencing Reform Act of 1984, abolishing indeterminate criminal sentencing, establishing the U.S. Sentencing Commission within the judicial branch, and empowering seven voting members to promulgate binding sentencing guidelines for federal judges, a constitutional delegation of criminal sentencing powers to an independent Sentencing Commission?Decision
It was held that the Sentencing Reform Act of 1984 was a constitutional delegation of powers.Justice Blackmun
Harry Blackmun
Harold Andrew Blackmun was an Associate Justice of the Supreme Court of the United States from 1970 until 1994. He is best known as the author of Roe v. Wade.- Early years and professional career :...
delivered the majority opinion. As society increases in complexity, Congress must delegate its job “under broad general directives”. The broad delegation “is sufficiently specific and detailed to meet constitutional requirements.”
Congress has three goals in mind (1) guarantee to uphold the Act passed (2) provide certainty and fairness (3) establish uniform criminal justice process.
Congress specified four purposes of sentencing. (1) Reflect seriousness of offense, (2) promote respect for the law, (3) provide just punishment, (4) afford adequate deterrence, and provide defendant with needed correctional treatment.
Congress set forth a guideline system to be personable for the specific case and placed 7 factors to consider when sentencing: grade of offense, aggravating circumstances, nature and degree of harm, community view, public concern, deterrent effect, current incidence.
Another 11 factors were established to summarize the defendant: age, education, vocational skills, mental and emotional condition, physical condition, previous employment, family ties and responsibilities, community ties, role in the offense, criminal history, and degree of dependence upon crime for livelihood. Congress prohibited the Commission from addressing race, sex, national origin, creed, and socioeconomic status.
Congress went into enumerated detail of the guidelines the Sentencing Commission more than an “intelligible principle”—-the requirement for delegation of power.
Dissent
Dissenting Justice ScaliaAntonin Scalia
Antonin Gregory Scalia is an American jurist who serves as an Associate Justice of the Supreme Court of the United States. As the longest-serving justice on the Court, Scalia is the Senior Associate Justice...
believed the sentencing commission to be an unconstitutional delegation of legislative power by Congress to another agency because the guidelines established by the Sentencing Commission have the force of law: a judge who disregards them will be reversed. Scalia noted that the guidelines were 'heavily laden (or ought to be) with value judgments and policy assessments' rather than merely technical, Scalia also disputed the assertion by majority that the sentencing commission was in the judicial branch rather than the legislative saying the commission "is not a court, does not exercise judicial power, and is not controlled by or accountable to members of the Judicial Branch,"
See also
- List of United States Supreme Court cases, volume 488
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court