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United States v. Haymond

139 S. Ct. 2369 (2019)

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United States v. Haymond

United States Supreme Court

139 S. Ct. 2369 (2019)

Facts

Andre Haymond (defendant) was convicted for possession of child pornography and sentenced to 38 months in prison followed by 10 years of supervised release. Haymond’s sentence was issued in accordance with the guidelines set forth in the Sentencing Reform Act of 1984 (SRA). After Haymond completed his prison term, a search of his phone turned up additional child pornography. The district judge, acting without a jury and applying the preponderance-of-the-evidence standard, found that Haymond had knowingly downloaded child pornography onto his phone and sentenced Haymond to an additional five years in prison. The additional prison term was issued pursuant to SRA Section 3583(k)’s mandatory minimum sentence for defendants who violated the terms of their supervised release by possessing child pornography. Haymond appealed the additional prison term. The Tenth Circuit held that Section 3583(k) was unconstitutional because it allowed judges to extend prison sentences beyond the original term without a jury trial. The federal government (plaintiff) appealed to the United States Supreme Court, arguing that (1) the Section 3583(k) penalties were authorized by the jury’s original verdict; and (2) like parole violations, supervised-release violations did not require a jury trial before imposition of penalties.

Rule of Law

Issue

Holding and Reasoning (Gorsuch, J.)

Concurrence (Breyer, J.)

Dissent (Alito, J.)

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