United States v. Haymond
2019 United States Supreme Court case / From Wikipedia, the free encyclopedia
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United States v. Haymond, 588 U.S. ___ (2019), is a case in which the U.S. Supreme Court struck down the five-year mandatory minimum prison sentence for certain sex offenses committed by federal supervised releases under 18 U.S.C. § 3583(k) as unconstitutional unless the charges are proven to a jury beyond a reasonable doubt.[2] Justices Ginsburg, Sotomayor, and Kagan joined Gorsuch's plurality opinion, while Breyer provided the necessary fifth vote with his narrow concurrence that began by saying he agreed with much of Justice Alito's dissent, which was joined by Justices Roberts, Thomas, and Kavanaugh.[3][4][5][6][7][8]
United States v. Haymond | |
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Argued February 26, 2019 Decided June 26, 2019 | |
Full case name | United States, Petitioner v. Andre Ralph Haymond |
Docket no. | 17-1672 |
Citations | 588 U.S. ___ (more) 139 S. Ct. 2369; 204 L. Ed. 2d 897 |
Case history | |
Prior | No. 08-CR-201, 2016 WL 4094886 (N.D. Okla. Aug. 2, 2016); affirmed, 869 F.3d 1153 (10th Cir. 2017); cert. granted, 139 S. Ct. 398 (2018). |
Subsequent | Appeal dismissed on remand, 935 F.3d 1059 (10th Cir. 2019). |
Holding | |
The U.S. Court of Appeals for the 10th Circuit's judgment – that 18 U.S.C. § 3583(k)'s last two sentences are unconstitutional and unenforceable – is vacated, and the case is remanded.[1] | |
Court membership | |
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Case opinions | |
Plurality | Gorsuch, joined by Ginsburg, Sotomayor, Kagan |
Concurrence | Breyer (in judgment) |
Dissent | Alito, joined by Roberts, Thomas, Kavanaugh |
Laws applied | |
U.S. Const. amend. VI |
The Court was considering whether Congress can require mandatory minimum prison sentences that exceed the minimum for the original offense, and allow maximum prison sentences that exceed the maximum for the original offense, in federal supervised release revocation cases where the facts were not proven to a jury beyond a reasonable doubt.[9] The supervised release statute requires only that there be a judge's finding by a preponderance of the evidence that a violation of federal supervised release has occurred.[10]
The U.S. Court of Appeals for the 10th Circuit, relying heavily on United States v. Booker, excised the offending provision,[11][12] which had been introduced in the Adam Walsh Child Protection and Safety Act of 2006, and whose required application in this case the sentencing judge had found "repugnant."[13]
Justice Samuel Alito noted in oral argument that this case has the potential to bring down the entire system of federal supervised release. According to a Congressional Research Service report, "The Supreme Court’s ultimate decision in Haymond could have significant implications going forward for the over 16,000 federal inmates currently incarcerated and the nearly 9,000 former federal inmates currently serving terms of supervised release for sex offenses, as well as for how Congress crafts laws concerning supervised release."[14]