Congress created the United States Sentencing Commission under the Sentencing Reform Act of 1984. This Commission was to attack the wide discrepancies in sentencing by federal court judges by creating sentencing guidelines for all federal offenses. It was to be part of the judicial branch, with members appointed by the President and approved by the Senate. John Mistretta (convicted of three counts of selling cocaine) claimed that the Act violated the delegation-of-powers principle by giving the Commission "excessive legislative powers." This case was decided together with United States v. Mistretta.
Did the Act violate the nondelegation doctrine of the Constitution?
The Court found the Act to be valid because although Congress cannot generally delegate its legislative power to another Branch, the nondelegation doctrine does not prevent Congress from obtaining assistance from coordinate Branches. The test of validity is that an "intelligible principle" must be established by the legislature where the agency of the delegated authority must adhere to specific directives that govern its authority. The delegation to the Commission was sufficiently detailed and specific to meet these requirements. The Commission was given substantial authority and discretion in setting the guidelines; however, Congress established a classification hierarchy for federal crimes that the Commission was to use as an outline for its work.
Decisions
Decision: 8 votes for United States, 1 vote(s) against Legal provision: 18 U.S.C. 3551
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Full Opinion by Justice Harry A. Blackmun
