Harmelin v. Michigan
Harmelin v. Michigan is a significant U.S. Supreme Court case that addresses the constitutionality of mandatory sentencing, particularly in relation to the Eighth Amendment's prohibition of "cruel and unusual punishment." The case involved Ronald Allen Harmelin, who received a mandatory life sentence for possessing 672 grams of cocaine, exceeding the 650-gram threshold established by Michigan law. Harmelin contended that his sentence was disproportionate to the crime and that the mandatory nature of his sentencing did not allow for consideration of mitigating circumstances.
The Supreme Court, in a decision led by Justice Antonin Scalia, upheld the sentence, arguing that the Eighth Amendment does not contain a proportionality provision for noncapital offenses. The ruling highlighted that while mandatory sentences can be severe, they are historically common in the U.S. legal system and not categorically deemed cruel and unusual. However, the decision opened the door for future challenges to mandatory sentencing by acknowledging that states have differing laws, which could lead to disparities in penalties for similar crimes. This case emphasizes the ongoing debate over the balance between legislative authority in establishing sentencing laws and the protections afforded to individuals under the Constitution.
Harmelin v. Michigan
The Case: U.S. Supreme Court ruling on mandatory sentences
Date: Decided on June 27, 1991
Significance: Upholding a Michigan drug possession law that carried a mandatory term of life imprisonment, the Supreme Court rejected the plaintiff’s argument that the sentence was “cruel and unusual punishment” and therefore in violation of the Eighth Amendment.
Under Michigan law, the petitioner, Ronald Allen Harmelin, was convicted of possessing 672 grams of cocaine and sentenced to mandatory life imprisonment because the amount was in excess of the 650-gram threshold specified in the law for imposing the mandatory sentence. The Michigan State Court of Appeals upheld the sentence, rejecting Harmelin’s claim that the sentence violated the protection against “cruel and unusual punishment” guaranteed by the Constitution. Harmelin argued that the sentence violated that restriction because it was “disproportionate” to his crime and, further, that because it was mandatory it provided for no “mitigating circumstances” that would allow a judge any latitude in sentencing.
Harmelin’s appeal to the U.S. Supreme Court was denied and his sentence upheld. Justice Antonin Scalia delivered the Court’s principal opinion. It concluded that because there is no proportionality provision in the Eighth Amendment, a sentence cannot be deemed cruel or unusual on the basis that it is disproportionate to the crime involved. Furthermore, it argued that Harmelin’s claim that his mandatory sentence deprived him of his right to a consideration of mitigating circumstances had no precedent in constitutional law. It observed that mandatory penalties, though they could be harsh or extreme, were common enough in the history of the United States and had never been construed as cruel and unusual in the constitutional sense of that phrase. While granting that Harmelin’s argument had support in the so-termed individualized capital-sentencing doctrine of the Court’s death-penalty legal theory, the majority dismissed Harmelin’s claim because of the qualitative difference between execution and all other forms of punishment.
Justice Anthony Kennedy, joined by Justices Sandra Day O’Connor and David Souter, although concurring with the judgment against Harmelin, claimed that the Eighth Amendment’s cruel and unusual punishment provision does encompass “a narrow proportionality principle that applies to noncapital sentences.” Citing various precedents, these justices argued that the Court, though not clearly or consistently, had previously determined the constitutionality of noncapital punishments based on that principle, although said precedents had taken under review only the length of a punishment’s term, not its type.
Having again broached the issue of proportionality, the Supreme Court was likely to face more challenges to mandatory sentencing. From state to state, in statutes imposing mandatory sentences, there is no uniform-sentencing code governing types of punishment or their length. Although in Harmelin the Court argued that state legislatures must retain the prerogative of establishing their own penal codes, where there is a wide discrepancy between mandatory penalties imposed for the same crime by one state and another, plaintiffs may seek relief from enforcement of the more severe penalty.
Bibliography
Gaines, Larry K., and Peter B. Kraska, eds. Drugs, Crime, and Justice. Prospect Heights, Ill.: Waveland Press, 2003.
Tonry, Michael. Reconsidering Indeterminate and Structured Sentencing. Washington, D.C.: U.S. Department of Justice, Office of Justice Programs, National Institute of Justice, 1999.
‗‗‗‗‗‗‗. Sentencing Matters. New York: Oxford University Press, 1996.
United States Sentencing Commission. Federal Sentencing Guidelines Manual 2003. St. Paul, Minn.: West Group, 2004.