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Mistretta v. United States

Supreme Court of the United States · 1989 · Constitutional Law

separation of powerssentencing commissiondelegationindependent agencySentencing Reform Act of 1984United States Sentencing CommissionSentencing Guidelinesnondelegation

Facts

Congress enacted the Sentencing Reform Act of 1984 to address sentencing disparity and uncertainty in the federal indeterminate sentencing system. The Act created the United States Sentencing Commission as an independent commission in the Judicial Branch, directed it to promulgate binding sentencing guidelines, and provided that at least three of its seven voting members be federal judges appointed by the President with Senate confirmation. Mistretta was indicted on federal cocaine charges, pleaded guilty to one count, and was sentenced under the Guidelines to 18 months' imprisonment plus supervised release, a fine, and a special assessment. He challenged the Guidelines on the ground that Congress delegated excessive authority to the Commission and violated separation of powers by structuring the Commission as it did.

Issue

Whether Congress violated the nondelegation doctrine by authorizing the Sentencing Commission to promulgate sentencing guidelines, and whether the Sentencing Reform Act violated separation of powers by creating an independent commission in the Judicial Branch with rulemaking authority, judicial members, and presidential appointment and limited removal of commissioners.

Rule

Congress may delegate authority if it lays down an intelligible principle directing the delegate's action; this requirement is satisfied when Congress clearly delineates the general policy, the agency to apply it, and the boundaries of the delegated authority. Separation of powers is violated only when a statutory arrangement improperly aggrandizes one Branch, encroaches on another, assigns to the Judiciary tasks more properly accomplished elsewhere, or impermissibly threatens the institutional integrity or constitutionally assigned functions of the Judicial Branch.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Congress creates the Federal Sentencing Policy Board, housed in Washington, D.C., and directs it to issue binding sentencing ranges for all federal fraud offenses. The statute identifies the board, instructs it to reduce unwarranted disparity, promote deterrence and just punishment, use sentencing ranges tied to offense and offender categories, consider listed aggravating and mitigating factors, forbid reliance on race and socioeconomic status, and stay within statutory maxima.

A defendant sentenced under the new ranges argues that Congress unconstitutionally delegated legislative power. How should a court rule?

Explanation. The delegation is valid. The majority held that Congress may obtain assistance from another body so long as it lays down an intelligible principle. That requirement is satisfied when Congress clearly delineates the general policy, the public agency to apply it, and the boundaries of the delegated authority. Here Congress did far more than announce a vague aspiration: it identified sentencing goals, required use of ranges, specified factors to consider and forbidden factors, and limited the ranges by existing statutory maxima. The majority specifically rejected the idea that broad discretion is unconstitutional when exercised within a detailed statutory framework.