William Freeman v. United States (564 U.S. 522)

U.S. Supreme Court · decided June 23, 2011 · Supreme Court Database (Spaeth)

Citation
564 U.S. 522 · 131 S. Ct. 2685
Decided
June 23, 2011
Term
October Term 2010
Vote
5–4
Majority author
Justice Kennedy
Issue area
Criminal Procedure
Disposition
Reversed and remanded
Outcome
Petitioning party won
Ideological direction
Liberal

Opinion excerpt

Justice Kennedy announced the judgment of the Court and delivered an opinion, in which Justice Ginsburg, Justice Breyer, and Justice Kagan join. The Sentencing Reform Act of 1984, 18 U. S. C. § 3551 et seq., calls for the creation of Sentencing Guidelines to inform judicial discretion in order to reduce unwarranted disparities in federal sentencing. The Act allows retroactive amendments to the Guidelines for cases where the Guidelines become a cause of inequality, not a bulwark against it. When a retroactive Guidelines amendment is adopted, § 3582(c)(2) permits defendants sentenced based on a sentencing range that has been modified to move for a reduced sentence. The question here is whether defendants who enter into plea agreements that recommend a particular sentence as a condition of the guilty plea may be eligible for relief under § 3582(c)(2). See Fed. Rule Crim. Proc. 11(c)(1)(C) (authorizing such plea agreements). The Court of Appeals for the Sixth Circuit held that, barring a miscarriage of justice or mutual mistake, defendants who enter into 11(c)(1)(C) agreements cannot benefit from retroactive Guidelines amendments. Five Members of the Court agree that this judgment must be reversed. The Justices who join this plurality opinion conclude that the categorical bar enacted by the Court of Appeals finds no support in § 3582(c)(2), Rule 11(c)(1)(C), or the relevant…

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