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Constitutional Law Keyed to Choper
Mistretta v. United States
Citation:
488 U.S. 361 (1989)Facts
In 1984, Congress passed the Sentencing Reform Act, which created the United States Sentencing Commission as an independent body within the judicial branch. The Commission was tasked with developing guidelines to eliminate sentencing disparities among federal courts. The Commission consists of seven voting members appointed by the President and confirmed by the Senate, with at least three being federal judges. John Mistretta was indicted in federal court for cocaine distribution, and after his motion challenging the constitutionality of the Guidelines was denied, he pleaded guilty while preserving his right to appeal the constitutional issue. He was sentenced to 18 months’ imprisonment under the Guidelines and subsequently challenged their validity on separation of powers grounds, arguing that Congress had improperly delegated legislative power and that the placement of the Commission in the judicial branch violated structural constitutional principles.
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