United States v. Booker Case Brief

Why is the case important?

This opinion comes from the consolidation of two cases dealing with sentencing enhancement.

Facts of the case

“In Blakely v. Washington (2004) the U.S. Supreme Court ruled the Sixth Amendment right to trial by jury required judges to use only facts proved to a jury to increase a sentence beyond the standard range.Following U.S. Sentencing Guidelines, a federal district court judge enhanced Freddie Booker’s sentence based on facts the judge determined. Booker appealed and the Seventh Circuit Court of Appeals ruled the guidelines violated the Sixth Amendment where they required sentences to be based on facts found by a judge.In another case, U.S. Sentencing Guidelines allowed a judge to sentence Ducan Fanfan to 188-235 months in prison based on facts the judge determined. The judge decided Blakely v. Washington prevented him from enhancing the sentence and sentenced Fanfan to 78 months. The federal government appealed directly to the U.S. Supreme Court. The Court consolidated the Booker and Fanfan cases.”

Question

This case presents a two pronged issue:
1) whether imposing an enhanced sentence under the U.S. Sentencing Guidelines, based on a judicial determination violates the Sixth Amendent, and if it does
2) whether the Sentencing Guidelines are unconstitutional.

Answer

The court held that where the sentencing guidelines allow judges to enhance sentences using facts not reviewed by juries it is a violation of the Sixth Amendment right to trial by jury. The guidelines were not altogether unconstitutional, but would be considered advisory as opposed to mandatory.

Conclusion

“Under the Sixth Amendment, any fact other than a prior conviction that was necessary to support a sentence exceeding the maximum authorized by the facts established by a plea of guilty or a jury verdict had to be admitted by a defendant or proved to a jury beyond a reasonable doubt. Therefore, 18 U.S.C.S. §§ 3553(b)(1) and 3742(e) were unconstitutional. The Guidelines were effectively advisory rather than mandatory

  • district courts were required to take the Guidelines into account but were not bound to apply them. Review of sentencing decisions was to be subject to an unreasonableness standard. The ruling was applicable to all cases on direct review.”
    • Case Brief: 2005
    • Petitioner: United States
    • Respondent: Freddie J. Booker
    • Decided by: Rehnquist Court

    Citation: 543 US 220 (2005)
    Argued: Oct 4, 2004
    Decided: Jan 12, 2005