Case Brief – Mistretta v. United States, 488 U.S. 361 (1989)

A U.S. Supreme Court case where the court interpreted delegation of power (constitutional delegation clause) – Mistretta v. United States, 488 U.S. 361 (1989).

Facts of the Case

             The appellant, John Mistretta, was indicted on three separate counts for his role in the sale and distribution of cocaine by a District Court in Western Missouri (JUSTIA US Supreme Court, 2017). He sought to challenge guidelines introduced by the United States Sentencing Commission and moved to have them deemed unconstitutional based on the argument that their enactment went against the non-delegation doctrine.

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Issues

In 1984, Congress assented to the Sentencing Reform Act with the primary aim of addressing prevalent discrepancies noted in the justice system’s punitive measures in criminal cases. This legislation also created provisions for the creation of the United States Sentencing Commission tasked with outlining new guidelines for criminal sentencing. The petitioner challenged this as contempt of the non-delegation doctrine and unconstitutional.

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Decisions (Holdings)

            The Supreme Court found the federal sentencing policy valid since it was well within the precincts of the constitution. This is because the constitutional delegation clause does not inhibit Congress from seeking support from coordinate Branches.

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 Reasoning

            The rationale of the ruling was based on the fact that Congress established the “intelligible principle” in delegating authority tothe United States Sentencing Commission (Fruchtman, 2016). Furthermore, the delegation met all requirements which ceded authority to the commission to create guidelines for criminal punishment informed by a classification pecking order for federal crimes.  

Separate Opinions

            It is noteworthy to acknowledge that the Supreme Court ruling also attracted dissenting voices. For instance, Justice Antonin Scalia viewed these apparent “guidelines” as influential in a criminal case since they are backed by law enforcement officers and the law. Thus, judges have no option other than to adhere to the stipulations provided.

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Analysis 

            Over the past century, Congress has participated actively in the creating a scope for judicial sentencing.  The Petitioner’s first argument was that Congress had violated the non-delegation doctrine by according excess discretion to the United States Sentencing Commission. In its ruling, the Supreme Court held that this was well within the bounds of the constitution since Congress can be backed by other branches of government while applying the “intelligible test” for validity.

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