Supreme Court of the United States

Buford v. United States

March 20, 2001532 U.S. 59

Summary

Justice Breyer delivered the unanimous opinion holding that appellate courts should deferentially review a district court’s determination whether prior convictions were functionally consolidated for sentencing under the Sentencing Guidelines. The Court emphasized the determination’s fact-bound nature, district judges’ greater familiarity with sentencing and consolidation practices, and the limited usefulness of appellate precedent in resolving such case-specific questions. It affirmed the Seventh Circuit’s judgment. There were no separate opinions.

Holding

  • The standard of appellate review governing a district court’s functional-consolidation determination under the Sentencing Guidelines.. A district court’s determination whether prior convictions were functionally consolidated for sentencing is reviewed deferentially, rather than de novo, even when the underlying facts are undisputed.

Docket 99-9073

Cited authorities

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