Supreme Court of the United States
United States, Petitioner v. Andre Ralph Haymond
June 26, 2019588 U.S. 634
Summary
A plurality of the Court, with Justice Breyer concurring in the judgment, held that applying 18 U.S.C. § 3583(k)'s mandatory minimum five-year prison term—triggered solely by a judge's preponderance-standard finding, without a jury, that a supervisee committed specified offenses—violated the Fifth and Sixth Amendments, because any fact that triggers a new mandatory minimum must be found by a jury beyond a reasonable doubt under the Apprendi–Alleyne line. The Court rejected the government's contentions that revocation is a postjudgment sentence-administration proceeding outside the Sixth Amendment, that the jury's verdict already authorized the added punishment, and that § 3583(k) resembles historic parole and probation revocation. Declining to choose between competing remedies, it vacated the Tenth Circuit's judgment and remanded for consideration of whether juries could be empaneled to find the triggering facts. Justice Alito, joined by The Chief Justice and Justices Thomas and Kavanaugh, dissented, arguing that revocation proceedings are not part of any criminal prosecution and that the plurality's reasoning threatens the entire supervised-release system.
Holding
- Whether § 3583(k)'s mandatory minimum five-year prison term, triggered by judge-found facts at a supervised-release revocation hearing without a jury and under a preponderance standard, violates the Fifth and Sixth Amendments.. Yes. As applied, § 3583(k) is unconstitutional: a jury must find beyond a reasonable doubt any facts that trigger a new mandatory minimum prison term, and the judge-found revocation facts here increased the legally prescribed range of allowable sentences from zero-to-ten years to a minimum of five years up to life.
- What remedy follows from the constitutional violation.. The Court declined to resolve the parties' competing remedial arguments and returned the case to the court of appeals to address in the first instance the government's argument that § 3583(k) can be enforced by empaneling a jury to find the triggering facts beyond a reasonable doubt, including whether that argument was adequately preserved.
Docket 17-1672
Cited authorities
- 105 Colum. L. Rev. 1967
- 18 U.S.C. § 2252
- 18 U.S.C. § 4205
- 88 N.Y.U. L. Rev. 958
- 18 U.S.C. § 3583
- 18 U.S.C. § 3583
- 18 U.S.C. § 3624
- 79 Geo. L.J. 1162