United States v. Booker, 543 U.S. 220 (2005)
Primary Holding
The Federal Sentencing Guidelines are unconstitutional as applied in a manner that requires judges to find facts by a preponderance of the evidence that increase a defendant's sentence beyond the statutory maximum, violating the Sixth Amendment right to a jury trial.
In the case of United States v. Booker, the Supreme Court decided that the rules used to determine prison sentences were unfair because they allowed judges to make decisions based on facts not proven to a jury. This matters because it means that judges can no longer impose harsher sentences based on their own findings; instead, a jury must decide all the facts that could affect a person's sentence. For consumers, this ruling helps protect their rights by ensuring that everyone gets a fair trial, where a jury has the final say on important facts that could lead to longer prison time. This case is relevant if someone is facing criminal charges and is concerned about how their sentence might be determined.
AI-generated plain-language summary to help you understand this case
In the case of United States v. Booker, Freddie J. Booker was charged with possession with intent to distribute over 50 grams of cocaine base (crack). The jury found him guilty based on evidence that he possessed 92.5 grams of crack, which under 21 U.S.C. § 841(a)(1) mandated a minimum sentence of 10 years and a maximum of life imprisonment. However, during sentencing, the District Court Judge determined, by a preponderance of the evidence, that Booker had actually possessed an additional 566 grams of crack and had obstructed justice. This led to a significantly higher sentencing range of 360 months to life imprisonment, resulting in Booker receiving a 30-year sentence. The procedural history began when Booker appealed his sentence, and the Court of Appeals for the Seventh Circuit ruled in his favor, holding that the application of the Federal Sentencing Guidelines violated his Sixth Amendment rights. The court found that the judge's reliance on facts not determined by the jury, which increased his sentence beyond what the jury had found, was inconsistent with the Supreme Court's prior rulings in Apprendi v. New Jersey and Blakely v. Washington. The Seventh Circuit's decision was made despite a dissent from Judge Easterbrook, who disagreed with the majority's interpretation. The relevant background context includes the Supreme Court's evolving interpretation of the Sixth Amendment in relation to sentencing guidelines. The Court had previously established in Apprendi that any fact increasing a sentence beyond the statutory maximum must be proven to a jury beyond a reasonable doubt. The subsequent decision in Blakely reinforced this principle, leading to the conclusion that the mandatory nature of the Sentencing Guidelines, as applied in Booker's case, was unconstitutional. This case ultimately raised significant questions about the balance of judicial discretion and jury findings in the sentencing process.
Whether an application of the Federal Sentencing Guidelines violated the Sixth Amendment by allowing a judge to impose a sentence based on facts not found by a jury beyond a reasonable doubt.
The judgment is reversed and remanded.
- Court
- Supreme Court
- Decision Date
- October 4, 2004
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Stevens
- Damages Awarded
- N/A
- Data Quality
- high
Kimbrough v. United States, 552 U.S. 85 (2007)
Consumer WonThe United States Sentencing Guidelines are advisory rather than mandatory, allowing district courts to consider the disparity between crack and powder cocaine offenses when determining an appropriate sentence, and a sentence outside the Guidelines range is not per se unreasonable if it is based on such considerations.
Moore v. United States, 555 U.S. 1 (2008)
Consumer WonA district court must recognize its discretion to consider the disparity between the sentencing guidelines for crack and powder cocaine offenses when determining a sentence, as established by the Supreme Court's decision in Kimbrough v. United States.
Cunningham v. California, 549 U.S. 270 (2007)
Consumer WonThe California determinate sentencing law violates a defendant's right to a jury trial under the Sixth and Fourteenth Amendments by allowing a judge to impose a sentence above the statutory maximum based on facts not found by a jury or admitted by the defendant.
Burgess v. United States, 553 U.S. 124 (2008)
Consumer LostThe term “felony drug offense” in 21 U.S.C. §841(b)(1)(A) is defined exclusively by 21 U.S.C. §802(44) and includes state drug offenses that are punishable by imprisonment for more than one year, regardless of whether the state law classifies the offense as a misdemeanor.