United States v. Haymond

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Criminal Law
  • Date Filed: June 26, 2019
  • Case #: 17-1672
  • Judge(s)/Court Below: GORSUCH, J., announced the judgment of the Court and delivered an opinion, in which GINSBURG, SOTOMAYOR, and KAGAN, JJ., joined. BREYER, J., filed an opinion concurring in the judgment. ALITO, J., filed a dissenting opinion, in which ROBERTS, C.J., and THOMAS and KAVANAUGH, JJ., joined.
  • Full Text Opinion

The mandatory minimum sentence imposed by 18 U.S.C. § 3853(k) violates the right to a trial by jury guaranteed by the Fifth and Sixth Amendments.

Respondent was sentenced to thirty-eight months in prison and ten years of supervised release for possessing child pornography. Respondent violated the terms of his supervised release and the United States sought to impose a new prison sentence under 18 U.S.C. § 3583(k), which imposes a mandatory minimum of five years to life and disregards the length of the original sentence. Respondent appealed to the Tenth Circuit, which held that § 3583(k) violated the Fifth and Sixth Amendments. As a remedy the court struck the language concerning the mandatory minimum. The Supreme Court concluded that the statute is unconstitutional but made no ruling on the issue of remedy, remanding the issue to the court of appeals. The Court reasoned that precedent requires a jury to make factual findings beyond a reasonable doubt in order to “authorize a judicial punishment” and that a judge making such findings by a preponderance of the evidence standard “cannot stand.” Alleyne v. United States, 570 U.S. 99, 117 (2013). Furthermore, the Court reasoned that the usurpation of the jury function by a judge divests citizens of their control over the judicial branch. Blakely v. Washington, 542 U.S. 296, 306 (2004). Therefore, 18 U.S.C. § 3583(k) is unconstitutional. VACATED and REMANDED.

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