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Spears v. United States

United States Supreme Court
 555 U.S. 261 (2009)


Facts

The federal government (plaintiff) successfully prosecuted Steven Spears (defendant) for conspiracy to distribute cocaine in both its crack and powder forms. Under the United States Sentencing Guidelines (USSG), the recommended sentence for Spears' crime was 324 to 405 months' imprisonment. At the time, and until 2010, the USSG maintained a 100:1 ratio between powder and crack cocaine quantities, meaning that the USSG-recommended sentence for a crime involving one gram of crack cocaine was the same as for a crime involving 100 grams of powder cocaine. The federal district court judge shared the opinion of many other judges that the 100:1 ratio was disproportionately severe. The federal Sentencing Commission agreed with those judges, and had recommended that Congress lower the ratio to 20:1, even in routine ("heartland" or "mine-run") cases. The judge substituted that 20:1 ratio for the 100:1 ratio, which resulted in lowering Spears's sentence to 240 months. The government appealed, and the Eighth Circuit Court of Appeals reversed the judge's sentencing decision. Spears appealed to the Supreme Court, which vacated the Eighth Circuit's judgment. On remand, the Eighth Circuit once again struck down Spears's sentence on the grounds that the judge could not substitute his 20:1 ratio for the USSG's 100:1 ratio. The Supreme Court agreed to hear Spears's appeal once more.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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