Mistretta v. United States
|Mistretta v. United States|
Supreme Court of the United States
|Argued October 5, 1988
Decided January 18, 1989
|Full case name||John Mistretta v. United States|
|Citations||488 U.S. 361 (more)
109 S. Ct. 647; 102 L. Ed. 2d 714; 1989 U.S. LEXIS 434; 57 U.S.L.W. 4102
|Prior history||Cert. before judgment to the United States Court of Appeals for the Eighth Circuit|
|The Court found the Act to be valid because although Congress cannot generally delegate its legislative power to another Branch, the nondelegation doctrine does not prevent Congress from obtaining assistance from coordinate Branches|
|Majority||Blackmun, joined by Rehnquist, White, Marshall, Stevens, O'Connor, Kennedy; Brennan (all but n. 11)|
John Mistretta, who sold cocaine, 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 pled 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.
Was the Sentencing Reform Act of 1984, abolishing indeterminate criminal sentencing, establishing the United States 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?
It was held that the Sentencing Reform Act of 1984 was a constitutional delegation of powers.
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 for the Sentencing Commission, providing more than an “intelligible principle”—-the requirement for delegation of power.
Dissenting Justice Scalia 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,".