United States v. Booker
Citation and Court
543 U.S. 220 (2005), Supreme Court of the United States
Facts
Booker was convicted of drug offenses. The district judge, applying the mandatory Federal Sentencing Guidelines, found additional facts (quantity of drugs) by a preponderance of the evidence and imposed a sentence higher than the Guidelines range the jury’s verdict alone would have supported. The Seventh Circuit held this violated the Sixth Amendment under Blakely v. Washington.
Issue
Whether the mandatory Federal Sentencing Guidelines violate the Sixth Amendment by permitting judges to find facts that increase sentences beyond the maximum authorized by the jury’s verdict alone.
Holding
The mandatory Federal Sentencing Guidelines violate the Sixth Amendment; the remedy is to make the Guidelines advisory, requiring judges to consult them but retain discretion to impose sentences within the statutory range.
Rule / Doctrine
Under Apprendi v. New Jersey and Blakely v. Washington, any fact other than a prior conviction that increases the penalty beyond the prescribed statutory maximum must be submitted to a jury and proved beyond a reasonable doubt. Because the Guidelines mandatorily required judicial fact-finding to set sentence ranges, they were unconstitutional. The Court severed the mandatory provisions, leaving the Guidelines as advisory.
Significance
Booker fundamentally restructured federal sentencing. By making the Guidelines advisory, it restored judicial discretion and triggered ongoing debate about sentencing uniformity, disparate outcomes, and the proper role of the Sentencing Commission. Post-Booker appellate review uses an “abuse of discretion” standard under Gall v. United States.