Mistretta v. United States

Facts

Congress passed the Sentencing Reform Act of 1984, which set out to provide federal guidelines in the sentencing of federal crimes.  The Act established a Sentencing Commission which provided federal judges with guidelines for sentencing particular crimes.  Defendant was convicted of cocaine dealing and argued that the Commission was unconstitutionally given legislative powers proscribed only to Congress; and therefore, their sentencing guidelines were invalid.

Issue

Whether Congress can assign to a special committee the power of deciding federal sentencing guidelines.

Holding/Analysis

Yes, Congress constitutionally delegated its authority.  In passing the law, Congress had the policy goal of sentencing fairness.  The court held that Congressional delegation of its authority it more practical is a modern day setting because laws and society are so complex that Congress cannot by reasonably expected to legislate every matter and therefore must delegate its authority when necessary.

When delegating its authority, Congress need only articulate an “intelligible principle” for doing so.  In this case, the “intelligible principle” was to provide a more equal and fair sentencing guideline.  Moreover, Congress sought a deterrence policy and rehabilitation policy, both of which are sufficient to satisfy the “intelligible principle” doctrine.

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