Buford v. United States

RESPONDENT: United States
LOCATION: Florida Supreme Court

DOCKET NO.: 99-9073
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Seventh Circuit

CITATION: 532 US 59 (2001)
ARGUED: Jan 08, 2001
DECIDED: Mar 20, 2001

Dean A. Strang - Milwaukee, Wisconsin, argued the cause for petitioner
Paul R. Q. Wolfson - Argued the cause for respondent

Facts of the case

The United States Sentencing Guidelines define a career offender as one with at least two prior felony convictions for violent or drug-related crimes and provides that a sentencing judge must count as a single prior conviction all "related" convictions. Convictions may also be functionally related, if they were factually or logically related and sentencing was joint. After Paula Buford pleaded guilty to armed bank robbery, the sentencing judge had to determine whether her five prior state convictions were "related" or whether they should count as more than one. At sentencing, the government conceded that her four prior robbery convictions were related. The government did not concede that her prior drug conviction was related to the robberies. The District Court concluded that Buford's drug and robbery cases had not been either formally or functionally consolidated. In affirming, the Court of Appeals reviewed the decision deferentially rather than de novo, giving deference to the District Court.


Does a de novo standard of review apply when a court of appeals reviews a trial court's sentencing guideline determination as to whether an offender's prior convictions were consolidated, and thus related, for sentencing purposes?

Media for Buford v. United States

Audio Transcription for Oral Argument - January 08, 2001 in Buford v. United States

Audio Transcription for Opinion Announcement - March 20, 2001 in Buford v. United States

William H. Rehnquist:

The opinion of the Court in No. 99-9073, Buford against United States will be announced by the Justice Breyer.

Stephen G. Breyer:

This case raises a narrow question of federal sentencing law, a very narrow.

Imagine under the sentencing guidelines a trial court is supposed to determine whether an offender’s prior convictions were or were not consolidated, and if they were consolidated then they are related and if they are related they count as a single conviction, so, his sentence does not go up as much as if they were not consolidated.

Imagine the trial judge makes that determination and then the question before us is what standard of review should a Court of Appeals apply when it reviews that determination?

The relevant statute tells the Appeals Court to give due deference to the Trial Court’s decision.

The offender here wants de novo review and so the offender argues that the deference that is due is no deference at all.

The Court of Appeals rejected the offenders claim.

It thought that it should review the Trial Court’s determination deferentially and we conclude that the Court of Appeals was right.

Our reasons rest primarily upon the fact that the Trial Court is normally in a better position to determine, whether or not two earlier convictions had been consolidated.

The Trial Court is in a better position to make that determination than is the Court of Appeals.

Hence, we think that deference is called for.

We explain all this further along with certain other related matters in our opinion.

The decision is unanimous.