Paula L. Buford v. United States (532 U.S. 59)
U.S. Supreme Court · decided March 20, 2001 · Supreme Court Database (Spaeth)
- Citation
- 532 U.S. 59 · 121 S. Ct. 1276
- Decided
- March 20, 2001
- Term
- October Term 2000
- Vote
- 9–0
- Majority author
- Justice Breyer
- Issue area
- Criminal Procedure
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Conservative
Opinion excerpt
Justice Breyer delivered the opinion of the Court. This case raises a narrow question of sentencing law. What standard of review applies when a court of appeals reviews a trial court’s Sentencing Guideline determination as to whether an offender’s prior convictions were consolidated, hence “related,” for purposes of sentencing? In particular, should the appeals court review the trial court’s decision deferentially or de novo? We conclude, as did the Court of Appeals, that deferential review is appropriate, and we affirm. I A The trial court decision at issue focused on one aspect of the United States Sentencing Guidelines’ treatment of “career offenders,” a category of offender subject to particularly severe punishment. The Guidelines define a “career offender” as an offender with “at least two prior felony convictions” for violent or drug-related crimes. United States Sentencing Commission, Guidelines Manual §4B1.1 (Nov. 2000) (USSG). At the same time, they provide that a sentencing judge must count as a single prior felony conviction all those that are “related” to one another. USS6 § 4B1.2(c), and comment., n. 3; §4A1.2(a)(2). And they advise (in an application note) that prior convictions are “related” to one another when, inter alia, they “were consolidated for . . . sentencing.” §4A1.2, comment., n. 3. The Seventh Circuit has refined this “prior conviction” doctrine yet…
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