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United States v. Young

United States District Court for the Northern District of Iowa
960 F. Supp.2d 881 (2013)


Facts

The federal government (plaintiff) obtained the conviction of Douglas Young (defendant) on narcotics-related charges, in violation of 21 U.S.C. § 841. A § 841 conviction ordinarily carried a five-year prison sentence, but under 21 U.S.C. § 851, the sentence could be doubled because Young had a single prior conviction from 17 years earlier. Section 851 gave the prosecutor and the judge full discretionary authority to decide whether to apply the enhanced sentence. For over 40 years, prosecutors and judges lacked any Department of Justice guidance on how they should exercise their § 851 discretion. The attorney general issued the first such guidelines just weeks before the prosecutor and judge in Young's case had to decide whether he deserved an enhanced sentence.

Rule of Law

Issue

Holding and Reasoning (Bennett, J.)

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