Steven Spears v. United States (555 U.S. 261)
U.S. Supreme Court · decided January 21, 2009 · Supreme Court Database (Spaeth)
- Citation
- 555 U.S. 261 · 129 S. Ct. 840
- Decided
- January 21, 2009
- Term
- October Term 2008
- Vote
- 5–4
- Issue area
- Criminal Procedure
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Per Curiam. Steven Spears was found guilty of conspiracy to distribute at least 50 grams of cocaine base and at least 500 grams of powder cocaine, in violation of 21 U. S. C. §§ 841(a)(1), (b)(1)(A), (b)(1)(B), 846. At sentencing, the District Court determined that the drug quantities attributable to Spears yielded an offense level of 38, that his criminal history justified placing him in the Guidelines’ criminal history category IV, and that the resulting advisory Guidelines sentencing range was 324 to 405 months’ imprisonment. The District Court was of the view that the Guidelines’ 100:1 ratio between powder cocaine and crack cocaine quantities, see United States Sentencing Commission, Guidelines Manual §2Dl.l(c) (Nov. 2006) (USSG), yielded an excessive sentence in light of the sentencing factors outlined in 18 U. S. C. § 3553(a). Relying in part on decisions from other District Courts, see United States v. Perry, 389 F. Supp. 2d 278, 307-308 (RI 2005); United States v. Smith, 359 F. Supp. 2d 771, 781-782 (ED Wis. 2005), which in turn relied on a report from the Sentencing Commission criticizing the 100:1 ratio, see United States Sentencing Commission, Report to Congress: Cocaine and Federal Sentencing Policy 106-107, App. A, pp. 3-6 (May 2002) (hereinafter Report to Congress), the District Court recalculated Spears’ offense level based on a 20:1 crack-to-powder ratio. That…
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