Mistretta v. United States
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| Mistretta v. United States | |||||||||||||
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| Argued October 5, 1988 Decided January 18, 1989 |
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| Court membership | |||||||||||||
| Chief Justice: William Rehnquist Associate Justices: William J. Brennan, Byron White, Thurgood Marshall, Harry Blackmun, John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy |
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| Majority by: Blackmun Joined by: Rehnquist, White, Marshall, Stevens, O'Connor, Kennedy; Brennan (all but n. 11) Dissent by: Scalia |
Mistretta v. United States, 488 U.S. 361 (1989), is a case decided by the United States Supreme Court.
[edit] Background
John Mistretta, allegedly distributed cocaine, moved to have the sentencing guidelines ruled unconstitutional under excessive delegation of authority by Congress and violated the separation of powers. District Court denied his motion, and Mistretta plead guilty to conspiracy to distribute in exchange for dismissal of two other counts, and was sentenced to eighteen months. Later, Mistretta filed a petition to the Eighth Circuit, but both he and the government petitioned the Supreme Court and received certiorari.
[edit] Issues presented
Was the Sentencing Reform Act of 1984 [abolishing indeterminate criminal sentencing and established US Sentencing Commission, within the judicial branch, and empowered seven voting members to promulgate binding sentencing guidelines for federal judges] constitutional delegation of powers of criminal sentencing to an independent Sentencing Commission?
[edit] Decision
Held the Sentencing Reform Act of 1984 as a constitutional delegation of powers.
Opinions: 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 11 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.
Dissenting Justice Scalia holds the guidelines established by the Sentencing Commission have the force of law, because a judge that disregards them will be reversed. Scalia criticizes the judicial activism by calling their constitutional rulings merely a broad prescription of a white or black issue. It is interesting to note that Congress forbade taking the criminals socioeconomic status in sentencing.
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