UPDATES & ANALYSIS

6.05

U.S. Supreme Court denies reduced criminal sentences in appeal from Iowa

by Rox Laird | June 5, 2018

The U.S. Supreme Court denied an appeal from five Iowa criminal defendants who argued for shortened prison terms based on a recent change in federal sentencing guidelines.

The five defendants pleaded guilty to drug conspiracy charges that carried mandatory-minimum sentences of 20 years each. But because they provided “substantial assistance” to the criminal investigation, the government recommended sentence reductions, and U.S. District Judge Mark Bennett of Sioux City imposed prison terms ranging from 84 months to 264 months for the five.

Three years later the defendants sought reductions of their prison sentences following changes in sentencing guidelines approved by the U.S. Sentencing Commission, which were made retroactive.

Bennett denied the reductions, however, because the sentences he imposed below the 20-year mandatory minimum were based on a calculation factoring in the value of each defendant’s assistance to the government’s criminal investigation, not on the original U.S. Sentencing Commission guidelines.

The U.S. Court of Appeals for the Eighth Circuit upheld Bennett’s decision on appeal, and the U.S. Supreme Court in a unanimous ruling handed down Monday agreed with both.

“In each of petitioners’ cases, the top end of the [Sentencing Commission guidelines range] fell below the applicable mandatory minimum sentence, and so the court concluded that the mandatory minimum superseded the guidelines range,” Justice Samuel Alito Jr. wrote for the Supreme Court. “Thus, in all five cases, the court discarded the advisory ranges in favor of the mandatory minimum” to calculate the sentences.

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