Tapia v. United States

PETITIONER: Alejandra Tapia
RESPONDENT: United States
LOCATION: U.S. District Court for the Southern District of California

DOCKET NO.: 10-5400
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 564 US (2011)
GRANTED: Dec 10, 2010
ARGUED: Apr 18, 2011
DECIDED: Jun 16, 2011

ADVOCATES:
Matthew D. Roberts - Assistant to the Solicitor General, Department of Justice, for the respondent in support of vacatur
Reuben C. Cahn - for the petitioner
Stephanos Bibas - for amicus curiae (appointed by the Court)

Facts of the case

Alejandra Tapia was convicted of bringing illegal aliens into the United States and of jumping bail after being charged with immigration crimes. Following the jury trial, a judge on the U.S. District Court for the Southern District of California sentenced Tapia to 51 months in prison, noting that one factor in giving her a longer sentence was to make sure she remained confined long enough to take part in a drug rehab program.

Tapia appealed the sentence, arguing that the district court committed plain error by basing her sentence on speculation about whether and when she could enter and complete the Bureau of Prison's 500-hour drug abuse treatment program. But in April 2010, the U.S. Court of Appeals for the Tenth Circuit affirmed the lower court order.

Question

Can a district court give a defendant a longer prison sentence to promote rehabilitation?

Media for Tapia v. United States

Audio Transcription for Oral Argument - April 18, 2011 in Tapia v. United States

Audio Transcription for Opinion Announcement - June 16, 2011 in Tapia v. United States

Elena Kagan:

The question in this case is whether a federal judge can impose or lengthen a prison sentence because he believes that imprisonment will aid in a criminal offender's rehabilitation, for example, by enabling that person to get drug treatment.

Petitioner Alejandra Tapia was convicted of several federal crimes.

At sentencing, the judge chose a 51-month prison term for her sentence.

In explaining this sentence, the judge referred several times to Tapia's need for drug treatment, citing a prison rehabilitation program called the 500 Hour Drug Program.

The court said some things that suggested that Tapia should serve a prison term long enough to qualify for and to complete that program.

On appeal, Tapia argued that the judge had erred by lengthening her prison term to make her eligible for the 500 Hour Drug Program.

She argued that this violated a provision in the Sentencing Reform Act, which tells the sentencing court, and I'm quoting here, "to recognize that imprisonment is not an appropriate means of promoting correction and rehabilitation".

The Court of Appeals disagreed with Tapia.

We took this case to resolve a conflict among the Circuit Courts and we now reverse.

We agree with Tapia's interpretation.

Our decision starts with the text.

The provision at issue here, Section 3582, instructs sentencing courts, and I'm going to quote it again, "to recognize that imprisonment is not an appropriate means of promoting correction and rehabilitation".

That is a straightforward statement.

It tells a court that imprisonment is not a suitable sanction for the purpose of facilitating a criminal offender's rehabilitation.

And it tells courts that they should recognize this fact either when determining whether to impose a term of imprisonment or when determining the length of the term.

In other words, the defendant cannot be sentenced to prison to promote his rehabilitation and his sentence also cannot be lengthened for that reason.

The statutory context supports this conclusion.

There is another provision of the Sentencing Reform Act that says something quite similar to a different audience.

It tells the Federal Sentencing Commission to write Sentencing Guidelines that reflects the inappropriateness of imposing a sentence to a term of imprisonment for the purpose of rehabilitating the defendant.

That is the same message that Section 3582 sends to sentencing courts, do not use prison to promote the defendant's rehabilitation.

And we also note that Congress do not give judges the power to make sure the defendants actually gets treatment while behind bars.

That is yet another sign that Congress did not want judges to order imprisonment for that purpose.

The United States does not disagree with this interpretation of the statute.

In fact, it declines to defend the judgment of the Court of Appeals in this case.

And so, we appointed an amicus curiae, a friend of the Court, to make arguments on the other side.

The amicus we chose did an exceptionally good job, making a variety of arguments that rehabilitation may sometimes, under some circumstances, be taken into account as the basis for a prison sentence.

We address these arguments in the opinion, but here, it is enough to say that they are insufficient to overcome the clear statutory text.

Returning to the details of this case, the District Judge's statements suggest that he may have lengthened Tapia's sentence to ensure that she received drug treatment.

If so, the sentence would conflict with the Sentencing Reform Act.

We therefore reverse the judgment of the Court of Appeals and remand the case for further proceedings.