Mistretta v. United States

Congress enacted the Sentencing Reform Act of 1984 (the act) to combat serious disparities in sentencing for criminal punishment. The act: (1) rejected rehabilitation and declared that punishment should be “retributive, educational, deterrent, and incapacitative”; (2) created the United States Sentencing Commission (commission), which sets sentencing guidelines (guidelines); (3) made sentences essentially final; (4) imposed the guidelines on federal courts; and (5) authorized limited appellate review of sentences. The commission is an independent body in the judicial branch comprising members appointed by the president. At least three members must be judges. The commission must set, review, and revise the guidelines, report to Congress, set policies, and monitor and train judicial actors. John Mistretta (defendant) was indicted in federal court on drug charges. Mistretta moved for a declaration that the guidelines were unconstitutional on the grounds that the act violated the separation of powers and nondelegation doctrines. The district court concluded that the commission should be treated as an executive-branch entity and the guidelines as agency rules. Though the court expressed reservations about the act, it rejected Mistretta’s argument. Mistretta pled guilty and was sentenced to prison, pursuant to the guidelines. Mistretta filed notice of appeal. Before the Eighth Circuit ruled, Mistretta and the government petitioned the United States Supreme Court for certiorari, which was granted on the basis of “imperative public importance.”