Pulsifer v. United States
Pulsifer v. United States | |
Term: 2023 | |
Important Dates | |
Argued: October 2, 2023 Decided: March 15, 2024 | |
Outcome | |
Affirmed | |
Vote | |
6-3 | |
Majority | |
Elena Kagan • Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Brett Kavanaugh • Amy Coney Barrett | |
Dissenting | |
Neil Gorsuch • Sonia Sotomayor • Ketanji Brown Jackson |
Pulsifer v. United States is a case that was decided by the Supreme Court of the United States on March 15, 2024, during the court's October 2023-2024 term. The case was argued on October 2, 2023.
In a 6-3 ruling issued on March 15, 2024, the Court affirmed the United States Court of Appeals for the 8th Circuit ruling, holding, "A defendant facing a mandatory minimum sentence is eligible for safety-valve relief under 18 U. S. C. §3553(f)(1) only if he satisfies each of the provision’s three conditions—or said more specifically, only if he does not have more than four criminal-history points, does not have a prior three-point offense, and does not have a prior two-point violent offense."[1] Justice Elena Kagan penned the majority opinion. Justice Neil Gorsuch filed a dissenting opinion, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson. Click here for more information about the ruling.
The case came on a writ of certiorari to the United States Court of Appeals for the 8th Circuit. To review the lower court's opinion, click here.
Timeline
The following timeline details key events in this case:
- March 15, 2024: The U.S. Supreme Court affirmed the United States Court of Appeals for the 8th Circuit ruling.
- October 2, 2023: The U.S. Supreme Court heard oral argument.
- February 27, 2023: The U.S. Supreme Court agreed to hear the case.
- October 7, 2022: Mark Pulsifer appealed to the U.S. Supreme Court.
- July 11, 2022: The United States Court of Appeals for the 8th Circuit affirmed the U.S. District Court for the Southern District of Iowa’s opinion.
Background
Pulsifer v. United States is a case involving the First Step Act of 2018 and 18 U.S.C. § 3553(f)(1). The justices were asked to interpret the federal sentencing laws that allow some nonviolent offenders convicted of drug crimes to avoid mandatory minimum sentences. The provision of the sentencing law requires that a convicted defendant “does not have — (A) more than 4 criminal history points, excluding any criminal history points resulting from a 1-point offense, as determined under the sentencing guidelines; (B) a prior 3-point offense, as determined under the sentencing guidelines; and (C) a prior 2-point violent offense, as determined under the sentencing guidelines.”[3][4] In order to calculate a defendant's criminal history points, the United States Sentencing Commission adds points using the following guidelines:[5]
- 3 points for each prior sentence of imprisonment exceeding one year and one month
- 2 points for each prior sentence of imprisonment of at least sixty days not counted in (a)
- 1 point for each prior sentence not counted in (a) or (b), up to a total of 4 points for this subsection
- 2 points if the defendant committed the instant offense while under any criminal justice sentence, including probation, parole, supervised release, imprisonment, work release, or escape status
- 1 point for each prior sentence resulting from a conviction of a crime of violence that did not receive any points under (a), (b), or (c) above because such sentence was treated as a single sentence, up to a total of 3 points for this subsection
Pulsifer has asked whether a defendant is ineligible for relief under the sentencing guidelines if the defendant’s criminal history includes any of the disqualifying criteria or if they are ineligible only if all criteria are included.[3]
The provision has been reviewed by the Seventh, Eighth, and Ninth Circuit Courts. The Seventh and Eighth Circuits found that the and in the provision meant or, so any disqualifying criteria in a convicted defendant’s criminal record would render them ineligible for relief. The Ninth Circuit found that and meant and, requiring all disqualifying criteria in a convicted defendant’s criminal record to be present to render them ineligible for relief. The Eleventh Circuit Court will also review the provision.[6]
Questions presented
The petitioner presented the following questions to the court:
Questions presented:
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Oral argument
Audio
Audio of oral argument:[8]
Transcript
Transcript of oral argument:[9]
Outcome
In a 6-3 ruling issued on March 15, 2024, the Court affirmed the United States Court of Appeals for the 8th Circuit ruling, holding, "A defendant facing a mandatory minimum sentence is eligible for safety-valve relief under 18 U. S. C. §3553(f)(1) only if he satisfies each of the provision’s three conditions—or said more specifically, only if he does not have more than four criminal-history points, does not have a prior three-point offense, and does not have a prior two-point violent offense."[1] Justice Elena Kagan penned the majority opinion. Justice Neil Gorsuch filed a dissenting opinion, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson.
Opinion
In the court's majority opinion, Justice Elena Kagan wrote:[1]
“ | The “safety valve” provision of federal sentencing law exempts certain defendants from mandatory minimum penalties, thus enabling courts to give them lighter prison terms. To qualify for safety-valve relief, a defendant must meet various criteria, one of which addresses his criminal history. That criterion, in stylized form, requires that a defendant “does not have A, B, and C”—where A, B, and C refer to three ways in which past criminality may suggest future dangerousness and therefore warrant a more severe sentence. In brief (with details below), A, B, and C are“more than 4 criminal history points,” a “3-point offense,”and a “2-point violent offense.”
... In sum, Paragraph (f)(1)’s criminal-history requirement sets out an eligibility checklist. A defendant is eligible for safety-valve relief only if he satisfies each of the paragraph’s three conditions. He cannot have more than four criminal-history points. He cannot have a prior three-point offense. And he cannot have a prior two-point violent offense. Because Pulsifer has two prior three-point offenses totaling six points, he is not eligible. It makes no difference that he does not also have a prior two-point violent offense. Accordingly, we affirm the judgment of the Court of Appeals for the Eighth Circuit.[7] |
” |
—Justice Elena Kagan |
Dissenting opinion
Justice Neil Gorsuch filed a dissenting opinion, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson.
In his dissent, Justice Gorsuch wrote:[1]
“ | The First Step Act of 2018 may be “ ‘the most significant criminal justice reform bill in a generation.’” Brief for Sen. Richard J. Durbin et al. as Amici Curiae in Terry v. United States, O. T. 2020, No. 20–5904, p. 9. Through the 1980s and 1990s, Congress adopted an ever-increasing number of ever-longer mandatory minimum prison sentences. In part due to these policies, the federal prison population grew by more than 100% in less than a decade. In the First Step Act, Congress sought to recalibrate its approach. It did so by promising more individuals the chance to avoid one-size-fits-all mandatory minimums and receive instead sentences that account for their particular circumstances and crimes.
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” |
—Justice Neil Gorsuch |
Text of the opinion
Read the full opinion here.
October term 2023-2024
The Supreme Court began hearing cases for the term on October 3, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[10]
See also
External links
- Search Google News for this topic
- U.S. Supreme Court docket file - Pulsifer v. United States (petitions, motions, briefs, opinions, and attorneys)
- SCOTUSblog case file for Pulsifer v. United States
Footnotes
- ↑ 1.0 1.1 1.2 1.3 U.S. Supreme Court, Pulsifer v. United States, decided March 15, 2024
- ↑ 2.0 2.1 SCOTUSblog, "Pulsifer v. United States," February 27, 2023
- ↑ 3.0 3.1 SCOTUSblog, "Another separation-of-powers case, press access to trials, and maritime insurance," February 23, 2023
- ↑ SCOTUSblog, "Court will review constitutionality of consumer-watchdog agency’s funding," February 27, 2023
- ↑ UNITED STATES SENTENCING COMMISSION, "2018 CHAPTER 4," accessed March 23, 2023
- ↑ SupremeCourt.gov, "MARK E. PULSIFER, PETITIONER v. UNITED STATES PETITION FOR A WRIT OF CERTIORARI," October 07, 2022
- ↑ 7.0 7.1 7.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Supreme Court of the United States, "Oral Argument - Audio," argued October 2, 2023
- ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued October 2, 2023
- ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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