Greenlaw v. United States, 554 U.S. 237 (2008)
Primary Holding
A United States Court of Appeals cannot, on its own initiative, increase a defendant's sentence absent a Government appeal or cross-appeal.
In the case of Greenlaw v. United States, the Supreme Court decided that a higher court (the Court of Appeals) cannot increase a defendant's sentence on its own without the government asking for it. This matters because it protects defendants from unexpected and unfair increases in their sentences, ensuring that any changes must come from the prosecution. This case is relevant if someone is appealing a sentence and wants to know that their sentence cannot be made longer unless the government requests it.
AI-generated plain-language summary to help you understand this case
In *Greenlaw v. United States*, 554 U.S. 237 (2008), the underlying events involved Michael Greenlaw, a gang member involved in the sale of crack cocaine in Minneapolis. He was charged with eight offenses related to drug trafficking and firearms. After a trial, Greenlaw was convicted on seven counts, including two violations of 18 U.S.C. §924(c)(1)(A) for carrying and discharging a firearm during drug-related crimes. The District Court sentenced him to a total of 442 months in prison, which included a 5-year sentence for the first §924(c) conviction and a 10-year sentence for the second, but the court mistakenly ruled that the second conviction did not qualify as "second or subsequent" under the statute, which would have mandated a 25-year minimum sentence. The procedural history of the case began with Greenlaw's appeal of his sentence, during which he argued that it was unreasonably long. The Eighth Circuit Court of Appeals, however, found that the District Court had erred in its interpretation of the law regarding the §924(c) convictions. Acting on its own initiative, the appellate court determined that Greenlaw's sentence should be increased by 15 years, resulting in a new total of 622 months. This decision was made without any appeal or cross-appeal from the government. The relevant background context includes the statutory framework of 18 U.S.C. §924(c), which imposes mandatory minimum sentences for firearm offenses related to violent crimes or drug trafficking. The law stipulates that subsequent convictions carry significantly harsher penalties, and sentences must run consecutively. The Supreme Court's decision ultimately addressed the authority of appellate courts to modify sentences without a request from the government, concluding that such an increase was not permissible in this case.
Whether a United States Court of Appeals, acting on its own initiative, may order an increase in a defendant’s sentence without a Government appeal or cross-appeal.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- April 15, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Ginsburg
- Damages Awarded
- N/A
- Data Quality
- high
United States v. Rodriquez, 553 U.S. 377 (2008)
Consumer LostA state drug-trafficking conviction qualifies as a "serious drug offense" under the Armed Career Criminal Act if the maximum term of imprisonment prescribed by law for the offense is ten years or more, including recidivist enhancements.
Rita v. United States, 551 U.S. 338 (2007)
Consumer LostFederal courts of appeals may presume that a sentence imposed within a properly calculated United States Sentencing Guidelines range is a reasonable sentence when reviewing federal sentences for unreasonableness.
Gall v. United States, 552 U.S. 38 (2007)
Consumer WonCourts of appeals must review all sentences—whether inside, just outside, or significantly outside the Federal Sentencing Guidelines range—under a deferential abuse-of-discretion standard, and a sentence imposed by a district judge is presumed reasonable if it is within the Guidelines range.
Shepard v. United States, 544 U.S. 13 (2005)
Consumer LostA sentencing court under the Armed Career Criminal Act (ACCA) may not consider police reports or complaint applications to determine whether a prior guilty plea necessarily admitted to generic burglary; it is generally limited to examining the statutory definition, charging document, written plea agreement, transcript of plea colloquy, and any explicit factual finding by the trial judge to which the defendant assented.