Molinaâmartinez v. United States (578 U.S. 189)
U.S. Supreme Court · decided April 20, 2016 · Supreme Court Database (Spaeth)
- Citation
- 578 U.S. 189 · 136 S. Ct. 1338
- Decided
- April 20, 2016
- Term
- October Term 2015
- Vote
- 8–0
- Majority author
- Justice Kennedy
- Issue area
- Criminal Procedure
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice KENNEDY delivered the opinion of the Court. This case involves the Federal Sentencing Guidelines. In sentencing petitioner, the District Court applied a Guidelines range higher than the applicable one. The error went unnoticed by the court and the parties, so no timely objection was entered. The error was first noted when, during briefing to the Court of Appeals for the Fifth Circuit, petitioner himself raised the mistake. The Court of Appeals refused to correct the error because, in its view, petitioner could not establish a reasonable probability that but for the error he would have received a different sentence. Under that court's decisions, if a defendant's ultimate sentence falls within what would have been the correct Guidelines range, the defendant, on appeal, must identify "additional evidence" to show that use of the incorrect Guidelines range did in fact affect his sentence. Absent that evidence, in the Court of Appeals' view, a defendant who is sentenced under an incorrect range but whose sentence is also within what would have been the correct range cannot demonstrate he has been prejudiced by the error. Most Courts of Appeals have not adopted so rigid a standard. Instead, in recognition of the Guidelines' central role in sentencing, other Courts of Appeals have concluded that a district court's application of an incorrect Guidelines range can itself serve…
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