Chavez-Meza v. United States

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Sentencing
  • Date Filed: June 18, 2018
  • Case #: 17-5639
  • Judge(s)/Court Below: BREYER, J., delivered the opinion of the Court, in which ROBERTS, C. J., and THOMAS, GINSBURG, and ALITO, JJ., joined. KENNEDY, J., filed a dissenting opinion, in which SOTOMAYOR and KAGAN, JJ., joined. GORSUCH, J., took no part in the consideration or decision of the case.
  • Full Text Opinion

Where the record demonstrates that a judge has expressed a reasoned basis for a non-proportional sentence reduction, the explanation is adequate to support the sentence reduction.

Petitioner was charged with and convicted of possession of methamphetamine with intent to distribute. The district court judge reviewed the sentencing guidelines, determining that the applicable range was 135-168 months and imposed the lowest sentence available, 135 months. Later the sentencing guidelines lowered the applicable range to 108-135 months. Defendant sought a proportionate sentence reduction. The same district court judge imposed a sentence of 114 months rather than a proportional sentence reduction. Defendant appealed arguing that the judge should have provided a more specific explanation for the imposition of a non-proportional sentence. The Ninth Circuit Court of Appeals affirmed. The Supreme Court held that the record demonstrated a reasoned basis for the judge’s decision, and thus the explanation for the sentence reduction was adequate. The Court reasoned that when choosing a range from the guidelines, a judge’s choice reflects his belief that the chosen range is the correct range based on the factors in 18 U.S.C. § 3553(a). If the ranges are subsequently lowered, a judge may choose a non-proportional sentence within the new range. The judge took the factors articulated in § 3553(a) into consideration when making his choice, and thus his explanation was adequate. AFFIRMED.

Advanced Search

Back to Top