Spears v. United States

Summary

In a per curiam summary reversal, the Supreme Court held that under its decision in Kimbrough, district courts are entitled to reject and vary categorically from the crack-cocaine Guidelines based on policy disagreement with the 100:1 crack-to-powder ratio, even in a mine-run case presenting no individualized mitigating circumstances, and that a judge empowered to reject that ratio necessarily possesses the power to substitute a replacement ratio of his own choosing. Because the Eighth Circuit's en banc decision held to the contrary, the Court granted certiorari, reversed, and remanded. Chief Justice Roberts, joined by Justice Alito, dissented, contending that no error was apparent enough to warrant summary reversal and that the replacement-ratio question was arguably distinct from Kimbrough and should be left to percolate in the courts of appeals.