United States v. Greene

Summary

The court denied Rodney Greene’s motion under Federal Rule of Criminal Procedure 35(a) to correct special assessments imposed under 18 U.S.C. § 3013. Rejecting the Ninth Circuit’s contrary reasoning in United States v. Munoz-Flores, the court held that § 3013 was not a revenue-raising bill subject to the Origination Clause because its primary purpose was to support crime-victim assistance programs.

Holdings

1. Section 3013 is not a revenue-raising bill for purposes of the Origination Clause because its primary purpose was to assist victims of crime, while any governmental revenue it generated was incidental.
2. The special assessments imposed under 18 U.S.C. § 3013 were constitutional, so Greene's Rule 35(a) motion to correct his sentence was denied.

Questions Presented

1. Whether 18 U.S.C. § 3013 is a revenue bill subject to the Origination Clause of Article I, § 7.
2. Whether the special assessments imposed under § 3013 were constitutionally valid and should be corrected under Federal Rule of Criminal Procedure 35(a).

Disposition

other