United States v. Batchelder
Citation and Court
442 U.S. 114 (1979), Supreme Court of the United States
Facts
Batchelder was convicted under a statute that prohibited convicted felons from receiving firearms, carrying a maximum five-year sentence, rather than under a different but overlapping federal statute covering the same conduct with a maximum two-year sentence. He argued the prosecutor’s ability to choose between the two statutes was an unconstitutional delegation of legislative power and violated due process and equal protection.
Issue
Whether a prosecutor violates due process or equal protection by charging a defendant under one of two overlapping federal statutes with different maximum penalties for identical conduct.
Holding
A prosecutor’s decision to charge under either of two overlapping statutes carrying different penalties does not violate due process, equal protection, or the non-delegation doctrine.
Rule / Doctrine
When Congress enacts two statutes covering the same conduct with different penalties, the choice of which statute to charge under lies within the prosecutor’s broad discretion. This does not constitute an unconstitutional delegation of legislative authority or a due process violation, so long as the charging decision is not based on impermissible criteria such as race or the exercise of a constitutional right.
Significance
Batchelder affirms the breadth of prosecutorial charging discretion and the constitutional permissibility of overlapping criminal statutes. It is a key case for the proposition that disparate charging under overlapping laws is a structural feature of American criminal law, not an equal protection or due process problem.