United States v. Haymond

United States v. Haymond
Argued February 26, 2019
Decided June 26, 2019
Full case nameUnited States, Petitioner v. Andre Ralph Haymond
Docket no.17-1672
Citations588 U.S. ___ (more)
139 S. Ct. 2369; 204 L. Ed. 2d 897
Case history
PriorNo. 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).
SubsequentAppeal 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
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Neil Gorsuch · Brett Kavanaugh
Case opinions
PluralityGorsuch, joined by Ginsburg, Sotomayor, Kagan
ConcurrenceBreyer (in judgment)
DissentAlito, joined by Roberts, Thomas, Kavanaugh
Laws applied
U.S. Const. amend. VI

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]

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]

  1. ^ "United States v. Haymond". SCOTUSblog.
  2. ^ United States v. Haymond, No. 17-1672, 588 U.S. ___ (2019).
  3. ^ Zubizarreta, Tim (June 26, 2019). "Supreme Court rules mandatory sentence based on new crime during supervised release unconstitutional". www.jurist.org.
  4. ^ Foundation), Kevin Daley (Daily Caller News. "U S v Haymond". www.documentcloud.org.
  5. ^ "Gorsuch Sides with Liberals in Child Porn Sentencing Case (3)". news.bloomberglaw.com.
  6. ^ Stern, Mark Joseph (June 26, 2019). "Over Alito's Fuming Dissent, Gorsuch and the Liberals Protect the Right to Trial by Jury". Slate Magazine.
  7. ^ Blitzer, Ronn (June 26, 2019). "Gorsuch sides with liberal bloc once more, in sex offender case". Fox News.
  8. ^ "Supreme Court rules jury trial required in some supervised release revocations". The Washington Times.
  9. ^ Mark Joseph Stern (February 26, 2019). "United States v. Haymond: Gorsuch and Sotomayor defend Sixth Amendment right to a jury trial". Slate.com. Retrieved May 26, 2019.
  10. ^ Miller, Stephen A. (March 28, 2019). "US Supreme Court Considers Right to a Jury on Supervised Release | The Legal Intelligencer". Law.com. Retrieved May 26, 2019.
  11. ^ United States v. Haymond, 869 F.3d 1153 (10th Cir. 2017).
  12. ^ "United States v. Haymond | The George Washington Law Review". Gwlr.org. Retrieved May 26, 2019.
  13. ^ Rubin, Jordan S. "Lengthy Sex Offender Prison Terms at Risk at Supreme Court". News.bloomberglaw.com. Retrieved May 26, 2019.
  14. ^ Foster, Michael (November 27, 2018). "Which Punishment Fits Which Crime?: Supreme Court to Consider Whether Portion of Supervised Release Statute is Unconstitutional" (PDF). Congressional Research Service.

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