Irizarry v. United States, 553 U.S. 708 (2008)
Primary Holding
The Supreme Court held that Rule 32(h) of the Federal Rules of Criminal Procedure applies to any sentence that varies from the recommended Federal Sentencing Guidelines range, requiring the court to provide reasonable notice to the parties before contemplating such a variance, regardless of whether it is classified as a "departure.
In the case of Irizarry v. United States, the Supreme Court decided that when a judge wants to give a sentence that is different from what is normally recommended, they must inform everyone involved ahead of time. This matters because it ensures that people facing sentencing have a fair chance to prepare and respond to any changes that could affect their punishment. For consumers, this ruling protects their rights by making sure they are not surprised by unexpected sentences, allowing them to understand and challenge the decisions made in court. This case is relevant if someone is involved in a criminal case and is concerned about how their sentence might differ from what was initially suggested.
AI-generated plain-language summary to help you understand this case
In Irizarry v. United States, 553 U.S. 708 (2008), the underlying events involved Richard Irizarry, who pleaded guilty to making a threatening interstate communication under 18 U.S.C. § 875(c). On November 5, 2003, Irizarry sent an email threatening to kill his ex-wife and her new husband, having previously sent numerous similar emails in violation of a restraining order. The presentence report (PSR) indicated that he had also solicited another inmate to kill his ex-wife’s new husband and recommended a sentencing range of 41 to 51 months, citing enhancements for his multiple threats and violations of court orders. The procedural history of the case began with Irizarry's guilty plea, followed by a sentencing hearing where both the government and Irizarry presented evidence. The government intended to call Irizarry's ex-wife as a witness, who testified about the domestic violence and threats made against her and her family. Other witnesses, including an FBI agent and Irizarry's cellmate, provided additional context regarding Irizarry's intentions and behaviors. Irizarry objected to certain aspects of the PSR, particularly regarding the enhancements for his intentions and the lack of an adjustment for acceptance of responsibility. The case reached the Supreme Court on a writ of certiorari to the Eleventh Circuit, which had to determine whether Rule 32(h) of the Federal Rules of Criminal Procedure applied to all sentences that varied from the recommended Federal Sentencing Guidelines range, even if not classified as a "departure." The case highlighted the complexities surrounding sentencing procedures and the interpretation of guidelines in light of the defendant's actions and intentions.
Whether Rule 32(h) of the Federal Rules of Criminal Procedure applies to every sentence that is a variance from the recommended Federal Sentencing Guidelines range, even though not considered a “departure” as that term was used when the Rule was promulgated.
The judgment is reversed and remanded.
- Court
- Supreme Court
- Decision Date
- April 15, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Stevens
- Damages Awarded
- N/A
- Data Quality
- high
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.
Schriro v. Landrigan, 550 U.S. 465 (2007)
Consumer LostThe decision to grant an evidentiary hearing in federal habeas relief cases rests within the discretion of the district court, and such a hearing is not warranted if the applicant cannot make out a colorable claim of ineffective assistance of counsel.
Greenlaw v. United States, 554 U.S. 237 (2008)
Consumer WonA United States Court of Appeals cannot, on its own initiative, increase a defendant's sentence absent a Government appeal or cross-appeal.