Supreme Court of the United States
Wade v. United States
May 18, 1992504 U.S. 181
Summary
The Court unanimously held that the Government has discretion, rather than a duty, to file a substantial-assistance motion under 18 U.S.C. § 3553(e) and Sentencing Guideline § 5K1.1, but that district courts may review a refusal for unconstitutional motives. Relief is also available when the refusal lacks a rational relationship to any legitimate governmental end. A defendant must make a substantial threshold showing to obtain discovery or an evidentiary hearing; proof of assistance alone or generalized allegations of improper motive are insufficient. Because Wade offered only an account of his assistance, the Court affirmed the Court of Appeals' judgment. Justice Souter delivered the opinion, and there were no separate opinions.
Holding
- Whether substantial assistance obligates the Government to file a departure motion.. Section 3553(e) and Guideline § 5K1.1 give the Government a power, not a duty, to file a substantial-assistance motion.
- Whether prosecutorial refusals to file substantial-assistance motions are judicially reviewable.. District courts may review a refusal and grant relief when it rests on an unconstitutional motive, such as race or religion, or is not rationally related to any legitimate governmental end.
- Whether Wade's showing justified judicial inquiry or relief.. Wade was not entitled to relief or further inquiry because he failed to make a substantial threshold showing of an impermissible refusal.
Docket 91-5771