Jones v. United States
135 S. Ct. 8
| SCOTUS | 2014Background
- Supreme Court denies certiorari; Justice Scalia, joined by Thomas and Ginsburg, dissents from denial.
- Petitioners Jones, Thurston, and Ball were convicted of distributing small amounts of crack cocaine but acquitted of conspiring to distribute.
- Sentencing judge found they engaged in the charged conspiracy, using that finding to apply substantially higher Guidelines ranges.
- Petitioners contend Sixth and Fifth Amendment rights require jury findings for any fact that raises sentencing exposure.
- Rita v. United States and related cases discussed substantive reasonableness review; lower courts permitted judge-found facts to influence sentences within statutory ranges.
- Damage: petitioners sentenced to 180, 194, and 225 months despite jury acquittal on conspiracy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Sixth Amendment requires jury finding for any fact increasing penalty | Jones argues such facts must be proved to a jury beyond reasonable doubt. | United States argues judge-found facts within statutory ranges may determine sentence. | Certiorari denied; court did not resolve merits. |
| Effect of judge-found conspiracy finding on sentence | Jones contends the conspiracy finding violated Sixth Amendment since not jury-determined. | Government maintains it can rely on judge-found facts within range. | Certiorari denied; no merits decision. |
| Whether the petitioners' sentences were substantively unreasonable due to judge-found facts | Such facts can render sentences substantively unreasonable and unlawful. | Within-range sentences supported by judge-found facts may be permissible. | Certiorari denied; no merits decision. |
Key Cases Cited
- Rita v. United States, 551 U.S. 338 (U.S. 2007) (discusses substantive reasonableness review)
- Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (any fact increasing penalty is an element and must be proven to a jury)
- Gall v. United States, 552 U.S. 38 (U.S. 2007) (procedural reasonableness coupled with substantive limits on penalties)
- Almendarez-Torres v. United States, 523 U.S. 224 (U.S. 1998) (prior convictions may be found by a judge (with one noted dissent))
- United States v. Benkahla, 530 F.3d 300 (4th Cir. 2008) (addressed Sixth Amendment concerns about sentencing factors)
- United States v. Hernandez, 633 F.3d 370 (5th Cir. 2011) (upheld or discussed truths about judicial factfinding in sentencing)
- United States v. Ashqar, 582 F.3d 819 (7th Cir. 2009) (addressed jury versus judge findings in sentencing)
- United States v. Treadwell, 593 F.3d 990 (9th Cir. 2010) (examined judicial factfinding in sentencing)
- United States v. Redcorn, 528 F.3d 727 (10th Cir. 2008) (discussed role of judge-found facts in sentencing)