Sunday, November 3, 2013

United States v. Booker case brief

United States v. Booker case brief summary
543 U.S. 220 (2005)

In separate cases, two defendants were convicted of charges relating to cocaine distribution. The first defendant's sentence under the United States Sentencing Guidelines was reversed by the United States Court of Appeals for the Seventh Circuit. The government appealed the second defendant's sentence to the United States Court of Appeals for the First Circuit. The Supreme Court granted certiorari review in both cases.

The first defendant's sentence was increased under the Guidelines by more than eight years based, inter alia, on the trial judge's finding that defendant possessed a greater quantity of drugs than was found by the jury. In the second defendant's case, the trial judge made findings that would have added ten years to defendant's sentence, but the judge declined to apply the Guidelines' enhancement provisions.

  • The Supreme Court concluded that its Apprendi and Blakely decisions applied to the United States Sentencing Guidelines; under the Sixth Amendment, any fact other than a prior conviction that was necessary to support a sentence exceeding the maximum authorized by the facts established by a plea of guilty or a jury verdict had to be admitted by a defendant or proved to a jury beyond a reasonable doubt. 
  • Therefore, 18 U.S.C.S. §§ 3553(b)(1) and 3742(e) were unconstitutional. 
  • The Guidelines were effectively advisory rather than mandatory; district courts were required to take the Guidelines into account but were not bound to apply them. 
  • Review of sentencing decisions was to be subject to an unreasonableness standard. The Court's ruling was applicable to all cases on direct review.


The judgment of the Seventh Circuit was affirmed, and the matter was remanded for resentencing. In the second case, the judgment was vacated and remanded for resentencing under the system set out by the Supreme Court.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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