Mistretta v. United States
United States Supreme Court
The United States District Court for the Western District of Missouri ruled for the Defendant. The plaintiff appealed to the United States Court of Appeals for the Eight Circuit. Before the appeals court made a judgment, the United States Supreme Court granted certiorari.
Before the Sentencing Reform Act, the length of a sentence for a federal crime was determined by the sentencing judge and the Parole Commission. This Act, among other things, gives both of these jobs to United States Sentencing Commission.
In 1987, the plaintiff was indicted by the district court on three counts centering in a cocaine sale. The plaintiff claimed that the guidelines used to sentence him are constitutional.
Is the Sentencing Reform Act (The Act) of 1984, which created the United States Sentencing Commission an unconstitutional delegation of power from the legislature to an administrative branch?
Specifically, the plaintiff is arguing that Congress has granted the Commission "excessive legislative discretion" which violates the non-delegation doctrine (Article I, Section 1 of the Constitution). The court claims that while this is true, given the complexities of society, Congress cannot do its job without obtaining the assistance of other branches of the government and delegating power "under broad general directives." The court goes on to cite cases since 1935 which consistently uphold Congress' ability to delegate power under "broad standards."
After going through this background, the court says that the current Act in question is "sufficiently specific and detailed to meet constitutional requirements." The court goes on to list the specifics of the act including:
- goals of the act
- guidelines for regulating sentencing
- factors for formulating offense categories
- factors for establishing categories of defendants
- aggravating and mitigating circumstances
From these specifics, the court concludes that Congress actually "legislated a full hierarchy of punishment." And even though the commission has a significant amount of discretion, delegations may "carry with them the need to exercise judgment on matters of policy." The court, quoting Yakus v. United States, says that it would be only justified in saying there would be an "absence of standards for the guidance of the Administrator's action ... [if] it would be impossible in a proper proceeding to ascertain whether the will of Congress has been obeyed." ("Intelligible principle" doctrine). Further, Congress does not have to execute its policies involving the "least possible delegation of discretion to administrative officers."