Mistretta v. United States
| Mistretta v. United States | |
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| Argued October 5, 1988 Decided January 18, 1989 |
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| Full case name | John Mistretta v. United States |
| Citations | 488 U.S. 361 (more)
109 S. Ct. 647; 102 L. Ed. 2d 714; 1989 U.S. LEXIS 434; 57 U.S.L.W. 4102
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| Prior history | Cert. before judgment to the United States Court of Appeals for the Eighth Circuit |
| Holding | |
| The portion of the Sentencing Reform Act of 1984 establishing the U.S. Sentencing Commission did not violate separation of powers, because although Congress cannot generally delegate its legislative power to another Branch, the nondelegation doctrine does not prevent Congress from obtaining assistance from coordinate Branches. | |
| Court membership | |
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| Case opinions | |
| Majority | Blackmun, joined by Rehnquist, White, Marshall, Stevens, O'Connor, Kennedy; Brennan (all but n. 11) |
| Dissent | Scalia |
| Laws applied | |
| U.S. Const. Art. III | |
Mistretta v. United States, 488 U.S. 361 (1989), is a case decided by the United States Supreme Court concerning the constitutionality of the United States Sentencing Commission.
John Mistretta was indicted in the United States District Court for the Western District of Missouri for allegedly selling cocaine. He moved to have the United States Federal Sentencing Guidelines, which had been established under the Sentencing Reform Act of 1984, declared unconstitutional due to an excessive delegation of authority by Congress, resulting in a violation of separation of powers. After the motion was denied, Mistretta pleaded guilty to one count of conspiracy and agreement to sell cocaine. He was sentenced principally to serve 18 months in prison. He filed an appeal to the Eighth Circuit, but he and the government both petitioned for certiorari before judgment, and the Supreme Court granted the petitions.
Was Congress's creation of a United States Sentencing Commission with the power to establish binding sentencing guidelines a constitutional delegation of authority?
The Court held that the Commission and the Guidelines represented a constitutional delegation of powers.
Justice Blackmun delivered the majority opinion. The Court held that, as society increases in complexity, Congress must delegate authority “under broad general directives." The broad delegation of power to the Commission was undoubtedly "sufficiently specific and detailed to meet constitutional requirements.”
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