United States v. Brittman

Summary

The court holds that the Sentencing Reform Act unconstitutionally delegated legislative authority to the United States Sentencing Commission, including authority over federal criminal penalties and the definition of criminal conduct. It also discusses severability and adopts a two-track sentencing approach pending appellate resolution of the Guidelines' constitutionality. The defendant was convicted of armed bank robbery under 18 U.S.C. § 2113(d).

Holdings

1. The Sentencing Reform Act unconstitutionally delegated to the Sentencing Commission Congress's authority to establish federal criminal penalties and define criminal conduct.
2. The promulgation of mandatory Sentencing Guidelines by the Commission constituted legislative action that could not become law without passage by both Houses of Congress and presentment to the President.
3. Placement of the Sentencing Commission within the judicial branch violated the Constitution, although that placement provision was severable from the remainder of the statute.
4. The inclusion of Article III judges on the Sentencing Commission violated separation-of-powers principles by assigning them nonjudicial legislative and executive functions and impairing judicial impartiality.
5. The Sentencing Reform Act unconstitutionally transferred sentencing discretion that Congress had left within statutory sentencing ranges from Article III judges to the Sentencing Commission and the Executive Branch.
6. The mandatory Guidelines violated due process and separation-of-powers principles by eliminating broad judicial discretion to impose individualized sentences within congressionally established ranges.

Questions Presented

1. Whether the Sentencing Reform Act unconstitutionally delegated Congress's legislative authority to the United States Sentencing Commission.
2. Whether promulgation of the Sentencing Guidelines violated the constitutional requirements of bicameralism and presentment.
3. Whether placing the Sentencing Commission within the judicial branch violated the Constitution.
4. Whether the composition of the Sentencing Commission, including Article III judges, violated separation-of-powers principles.
5. Whether the Sentencing Guidelines improperly assigned judicial sentencing discretion to the Sentencing Commission and the Executive Branch in violation of Article III.
6. Whether the mandatory Guidelines violated due process by eliminating individualized judicial sentencing.

Disposition

other