Case Citation:
Mistretta v. United States, 488 U.S. 361, 109 S. Ct. 647, 102 L. Ed. 2d 714, 57 U.S.L.W. 4102 (U.S. Jan. 18, 1989)
Background of Mistretta v. United States
The case of Mistretta v. United States revolves around the constitutionality of the United States Sentencing Guidelines, which were established by the Sentencing Reform Act of 1984. This Act created the United States Sentencing Commission, a body tasked with developing guidelines that would standardize sentencing across federal criminal cases in an effort to reduce disparities in sentencing for similar offenses.
The petitioner, John Mistretta, was indicted for the sale of cocaine in the United States District Court for the Western District of Missouri. Upon his conviction, Mistretta challenged the constitutionality of the Sentencing Reform Act, particularly arguing that the law delegated excessive legislative power to the Sentencing Commission.
Mistretta contended that this delegation violated the nondelegation doctrine, which prohibits Congress from transferring its legislative authority to another branch of government without providing clear and adequate guidance.
Mistretta’s motion to have the guidelines declared unconstitutional was denied by the District Court, and he subsequently pled guilty to one count of conspiracy to distribute cocaine. The case was appealed, and the Eighth Circuit Court of Appeals upheld the constitutionality of the guidelines. Both Mistretta and the government then petitioned for certiorari before judgment, which was granted by the Supreme Court.
Facts of Mistretta v. United States
In 1984, Congress passed the Sentencing Reform Act with the goal of reducing disparities in sentencing across federal courts. As part of the Act, Congress established the United States Sentencing Commission, an independent body within the judicial branch, tasked with creating sentencing guidelines for federal criminal cases. The guidelines were intended to reduce sentencing discretion, ensuring more uniformity in criminal sentences.
John Mistretta was indicted on three counts related to his involvement in a cocaine distribution conspiracy. In his defense, Mistretta argued that Congress had delegated excessive legislative power to the Sentencing Commission. Specifically, he argued that the guidelines were too vague and allowed the Commission to create rules with far-reaching legal consequences without clear instructions from Congress.
Mistretta argued that this delegation was unconstitutional because it violated the separation of powers principle by giving a non-legislative body (the Sentencing Commission) the authority to create laws with the force of binding legal rules.
Mistretta was sentenced according to the sentencing guidelines, which ultimately led him to appeal the decision on the grounds of the unconstitutional delegation of power. The Eighth Circuit Court ruled in favor of the government, rejecting the claim that the Sentencing Commission’s powers violated the nondelegation doctrine, and Mistretta v. United States proceeded to the U.S. Supreme Court for final determination.
Issues Presented
The main issue in Mistretta v. United States is whether Congress, in delegating to the United States Sentencing Commission the authority to promulgate sentencing guidelines for federal criminal offenses, violated the nondelegation doctrine by granting excessive legislative discretion.
Did Congress, by delegating the authority to establish sentencing guidelines for federal criminal offenses to the United States Sentencing Commission, violate the nondelegation doctrine by granting excessive legislative discretion?
Supreme Court’s Decision in Mistretta v. United States
In a 8-1 decision, the Supreme Court of the United States upheld the constitutionality of the Sentencing Reform Act of 1984 and the United States Sentencing Commission’s authority to promulgate binding sentencing guidelines.
The Court held that Congress’s delegation of power to the Sentencing Commission did not violate the nondelegation doctrine because Congress had provided sufficiently clear guidelines for the Commission to follow in exercising its powers. The Court ruled that Congress must delegate power in a way that provides “an intelligible principle”, and as long as the delegation adheres to this principle, it does not violate the Constitution.
The majority opinion, written by Justice Blackmun, emphasized that the intelligible principle test governs the constitutionality of delegations of power by Congress. According to the Court, Congress had provided clear and specific directives to the Sentencing Commission when it created the Sentencing Reform Act.
In particular, the Act listed seven factors that the Commission must consider when developing sentencing guidelines for federal criminal offenses. These factors included the nature of the offense, the degree of harm caused, the public concern generated by the crime, and the deterrent effects of a sentence.
Justice Blackmun argued that the delegation of authority to the Sentencing Commission was constitutionally permissible because the guidelines the Commission created were directed by specific goals established by Congress. The Court noted that while the Commission had significant authority in creating guidelines, it was still subject to congressional oversight and was constrained by the statutory directives laid out in the Sentencing Reform Act.
Justice Scalia, in his dissent, argued that the delegation of power to the Sentencing Commission violated the nondelegation doctrine. He asserted that while the Commission’s guidelines may be called “guidelines,” they had the same effect as laws, and thus their creation by a non-legislative body undermined the separation of powers.
Justice Scalia also criticized the fact that the guidelines were not fully subject to judicial review, contending that the scope of the delegation was too broad and left courts with limited ability to scrutinize the Commission’s decisions. According to Justice Scalia, the Act did not provide sufficiently clear standards for the Commission, and the delegation of legislative power to the judicial branch was unconstitutional.
Conclusion
In Mistretta v. United States, the Supreme Court upheld the constitutionality of the Sentencing Reform Act and the delegation of power to the United States Sentencing Commission. The Court applied the intelligible principle test to find that the guidelines were constitutional because Congress had sufficiently defined the standards and goals for the Commission’s work.
The Court’s ruling reinforced the legitimacy of delegating legislative powers when clear guidelines are provided and highlighted the balance between Congressional oversight and judicial authority in the federal sentencing process.