Why is the case important?
Defendant, after being convicted of bribery, received a reduced sentence based on the fact that she faced extraordinary parental responsibilities.
Facts of the case
Roy Lee Johnson had been serving time in federal prison for multiple drug and firearms felonies when two of his convictions were declared invalid. The District Court ordered his immediate release. Johnson’s 3-year term of supervised release that was yet to be served on the remaining convictions then went into effect. As a result of serving time for the two invalid convictions, Johnson had served 2.5 years’ too much prison time. After his release, Johnson filed a motion to credit the excess two and one-half years he was erroneously incarcerated toward his three-year supervised release sentence. The District Court denied relief, explaining that the supervised release commenced upon Johnson’s actual release from incarceration, not before. In reversing, the Court of Appeals accepted Johnson’s argument that his supervised release term commenced not on the day he left prison, but when his lawful term of imprisonment expired.
Can a defendant’s extraordinary family circumstances justify a downward departure in sentencing?
Yes. Judgment affirmed.
While the defendant’s family circumstances do not decrease her culpability, based on the special circumstances of the defendant’s family, the imposition of a greater sentence would create a significant hardship on her children, justifying the departure.
“The United States Court of Appeals affirmed defendant’s convictions for distribution of controlled substances and mail fraud, holding that the evidence was sufficient to support the convictions. The evidence included testimony that Johnson prescribed narcotics on request, that Johnson, in fear of prosecution, took precautions in prescribing narcotics, and that Johnson exchanged prescriptions for construction work. The Court determined that such evidence could establish that Johnson prescribed narcotics without a medical purpose and outside the course of professional practice. The Court also found that there was sufficient evidence to support findings that Johnson never treated another clinic physician, that Johnson was listed as his treating physician on insurance forms, and that the forms were submitted through the mail. The Court held that such evidence was sufficient for a mail fraud conviction. However, the Court vacated Johnson’s sentence and remanded for resentencing, holding that the district court erred in declining to apply a sentence enhancement for use of a special skill and that before departing downward for Johnson’s medical condition
- Case Brief: 1968
- Petitioner: United States
- Respondent: Johnson
- Decided by: Rehnquist Court
Citation: 529 US 53 (2000)
Argued: Dec 8, 1999
Decided: Mar 1, 2000