Mistretta v. United States
Mistretta v. United States is a landmark Supreme Court case from 1989 that addressed the constitutionality of the 1984 Sentencing Reform Act, which established the United States Sentencing Commission. This legislation aimed to reduce disparities in sentencing across federal courts by creating standardized guidelines for judges, who previously had significant discretion in sentencing decisions. The Supreme Court, in a decisive 8-1 ruling, upheld the act, with Justice Harry A. Blackmun emphasizing that the commission's structure did not violate the separation of powers doctrine. Conversely, Justice Antonin Scalia dissented, expressing concerns that the involvement of federal judges in a commission designed to guide sentencing encroached upon executive functions. The case is significant in discussions about judicial powers and the balance of authority among branches of government, particularly in the context of criminal justice reform. Mistretta v. United States remains a pivotal reference point for understanding the complexities of sentencing practices and the constitutional implications of legislative reforms in the judicial system.
Mistretta v. United States
Date: January 18, 1989
Citation: 488 U.S. 361
Issues: Judicial powers; separation of powers
Significance: The Supreme Court upheld the creation of the Criminal Sentencing Commission in 1984, despite its mixture of judicial and executive functions and personnel.
In order to provide more uniformity in sentencing of criminals, Congress passed the 1984 Sentencing Reform Act, which created the Sentencing Commission. The president appointed seven members to the commission, three of whom had to be federal judges selected from a list of six forwarded by the Judicial Conference. The commission was to create guidelines for improving uniformity of sentencing of criminals by federal judges, who previously had broad discretion. Although the law and commission raised separation of powers issues, the Supreme Court upheld the act by a vote of eight to one. In his opinion for the Court, Justice Harry A. Blackmun wrote that he did not see an essential conflict in the complex appointment arrangements and activities of the commission, departing from the example of Hayburn’s Case (1792). Justice Antonin Scalia dissented, arguing that this act unconstitutionally allowed federal judges to participate in executive branch activities.