United States v. Johnson | |
---|---|
Argued December 8, 1999 Decided March 1, 2000 | |
Full case name | United States v. Roy Lee Johnson |
Citations | 529 U.S. 53 ( more ) 120 S. Ct. 1114; 146 L. Ed. 2d 39; 2000 U.S. LEXIS 1735; 68 U.S.L.W. 4174; 2000 Cal. Daily Op. Service 1612; 2000 Daily Journal DAR 2217; 2000 Colo. J. C.A.R. 1079; 13 Fla. L. Weekly Fed. S 131 |
Court membership | |
| |
Case opinion | |
Majority | Kennedy, joined by unanimous |
United States v. Johnson, 529 U.S. 53 (2000), was a United States Supreme Court case.
Johnson was sentenced in federal court for multiple violations of federal criminal provisions. He was sentenced terms of imprisonment for the violations and, in addition, a three-year mandatory term of supervised release for the drug possession offenses. After he had served 2½ years in federal prison, two of his convictions, not including the drug possession convictions, were declared invalid; as a result, he had served too much prison time, which resulted in his being eligible for immediate release. [1]
He argued that his time in federal prison should be credited against his three years of supervised release. The District Court denied relief, and explained that (1) pursuant to 18 USCS 3624(e), the supervised release commenced upon the accused's actual release from incarceration, not before, and (2) granting the accused credit would undermine the United States Congress's aim of using supervised release to assist convicted felons in their transitions to community life. However, the United States Court of Appeals for the Sixth Circuit (1) accepted the accused's argument that his term of supervised release commenced when his lawful term of imprisonment expired, and (2) reversed the decision of the District Court (154 F3d 569). [2]
A unanimous U.S. Supreme Court, per Justice Kennedy, reversed the original decision. Relying heavily upon the actual language in 18 U.S.C. § 3624(e), the Court found that a period of supervised release cannot commence until the prisoner is actually released from incarceration. [1] The Court construed the supervised release statute to unambiguously dictate the commencement of supervision upon release from custody. The Supreme Court found no need to resort to other subsections of the statute because:
1) the statute was unambiguous: a supervised release term did not commence until an accused was "released from imprisonment," and the ordinary and commonsense meaning of "release" was to be freed from confinement; 3624(e) also provided that (a) a term of supervised release came after imprisonment, once the prisoner was released by the Bureau of Prisons to the supervision of a probation officer, and (b) supervised release did not run while an individual remained in the custody of the Bureau. [3]
2) the same terminology was not used in the different subsections;
3) there was no express reference between the relevant statutory subsections.
Congress intended supervised release conditions to assist individuals in their transition to community life. Supervised release serves a rehabilitative end distinct from those served by incarceration. Id. at 59. [4]
When Congress provides exceptions in a statute, it does not follow that courts have authority to create others. The proper inference... is that Congress considered the issue of exceptions and, in the end, limited the statute to the ones set forth. Id. at 58.
However, Justice Kennedy noted that the inmate could seek equitable relief in the district court pursuant to 18 U.S.C. § 3583(e)(2) (modification of conditions of supervised release) or 18 U.S.C. § 3583(e)(1) (trial court may terminate supervised release after expiration of one year if warranted by the defendant's conduct).
United States v. X-Citement Video, Inc., 513 U.S. 64 (1994), was a federal criminal prosecution filed in the United States District Court for the Central District of California in Los Angeles against X-Citement Video and its owner, Rubin Gottesman, on three charges of trafficking in child pornography, specifically videos featuring the underaged Traci Lords. In 1989, a federal judge found Gottesman guilty and later sentenced him to one year in jail and a $100,000 fine.
In Canada, England, and Wales, certain convicted persons may be designated as dangerous offenders and subject to a longer, or indefinite, term of imprisonment in order to protect the public. Other countries, including Denmark and parts of the United States have similar provisions of law.
The PROTECT Act of 2003 is a United States law with the stated intent of preventing child abuse as well as investigating and prosecuting violent crimes against children. "PROTECT" is a contrived acronym which stands for "Prosecutorial Remedies and Other Tools to end the Exploitation of Children Today".
Alabama v. Shelton, 535 U.S. 654 (2002), was a United States Supreme Court case in which the Court upheld the Alabama Supreme Court's ruling that counsel must be provided for the accused in order to impose a suspended prison sentence.
Almendarez-Torres v. United States, 523 U.S. 224 (1998), was a decision by the United States Supreme Court which confirmed that a sentencing enhancement based on a prior conviction was not subject to the Sixth Amendment requirement for a jury to determine the fact beyond a reasonable doubt.
Jones v. United States, 526 U.S. 227 (1999), is a United States Supreme Court case interpreting the federal carjacking statute, 18 U.S.C. § 2119, to set forth three distinct crimes, each with distinct elements. The Court drew this conclusion from the structure of the statute, under which two subsections provided for additional punishment if the defendant inflicts more serious harm. The Court also distinguished Almendarez-Torres v. United States, 523 U.S. 224 (1998), because that case allowed for sentencing enhancement based on a prior conviction.
Sporhase v. Nebraska ex rel. Douglas, 458 U.S. 941 (1982), was a case in which the United States Supreme Court decided that a Nebraska statute forbidding commercial exportation of water from Nebraska was unconstitutional in that it violated the dormant commerce clause.
Incapacitation in the context of criminal sentencing philosophy is one of the functions of punishment. It involves capital punishment, sending an offender to prison, or possibly restricting their freedom in the community, to protect society and prevent that person from committing further crimes. Incarceration, as the primary mechanism for incapacitation, is also used as to try to deter future offending.
Smith v. United States, 508 U.S. 223 (1993), is a United States Supreme Court case that held that the exchange of a gun for drugs constituted "use" of the firearm for purposes of a federal statute imposing penalties for "use" of a firearm "during and in relation to" a drug trafficking crime.
Geier v. American Honda Motor Company, 529 U.S. 861 (2000), was a United States Supreme Court case in which the Court held that a federal automobile safety standard pre-empted a stricter state rule. The Court held that Alexis Geier, who suffered severe injuries in a 1987 Honda Accord, could not sue Honda for failing to install a driver-side airbag – a requirement under District of Columbia tort law but not Federal law – because Federal law pre-empted the District's rule.
Offenses under United States federal law are grouped into different classes according to the maximum term of imprisonment defined within the statute for the offense. The classes of offenses under United States federal law are as follows:
United States federal probation and supervised release are imposed at sentencing. The difference between probation and supervised release is that the former is imposed as a substitute for imprisonment, or in addition to home detention, while the latter is imposed in addition to imprisonment. Probation and supervised release are both administered by the U.S. Probation and Pretrial Services System. Federal probation has existed since 1909, while supervised release has only existed since 1987, when it replaced federal parole as a means for imposing supervision following release from prison.
Porter v. Nussle, 534 U.S. 516 (2002), is a United States Supreme Court case in which the court settled an intercircuit conflict regarding civil procedure for prisoners seeking redress. The court held that prisoners alleging assaults by prison guards must meet §1997e(a)'s exhaustion requirement before commencing a civil rights action.
Barber v. Thomas, 560 U.S. 474 (2010), is a United States Supreme Court case in which the Court held, 6–3, that prisoners incarcerated in federal prisons are entitled to up to 54 days of "good time credits" for every year they are incarcerated, allowing federal inmates to reduce their sentence by up to 54 days per year of imprisonment for exhibiting good behavior. The case concerned how the United States Federal Bureau of Prisons should calculate "good time credits": whether they should be calculated based on the length of the sentence levied by the judge, or by the time actually served by the inmate.
DePierre v. United States, 564 U.S. 70 (2011), was a case in which the Supreme Court of the United States held that the use of the term "cocaine base" in 21 U.S.C. § 841(b)(1) refers to cocaine in its chemically basic form. The decision of the Court was unanimous, except with respect to Part III–A.
Lopez v. Davis, 531 U.S. 230 (2001), was a United States Supreme Court case decided in 2001. The case concerned the validity of a Bureau of Prisons regulation which lowered prisoners' sentences for completion of a substance abuse program. The statute however restricted this credit to those who did not engage in a felony aided by a firearm. The Court upheld the regulation over the dissent of three Justices.
Wong Wing v. United States, 163 U.S. 228 (1896), was a United States Supreme Court case in which the Court found that the Fifth and Sixth Amendments to the U.S. Constitution forbid the imprisonment at hard labor without a jury trial for noncitizens convicted of illegal entry to or presence in the United States.
Gundy v. United States, No. 17-6086, 588 U.S. ___ (2019), was a United States Supreme Court case that held that 42 U.S.C. § 16913(d), part of the Sex Offender Registration and Notification Act ("SORNA"), does not violate the nondelegation doctrine. The section of the SORNA allows the Attorney General to "specify the applicability" of the mandatory registration requirements of "sex offenders convicted before the enactment of [SORNA]". Precedent is that it is only constitutional for Congress to delegate legislative power to the executive branch if it provides an "intelligible principle" as guidance. The outcome of the case could have greatly influenced the broad delegations of power Congress has made to the federal executive branch, but it did not.
United States v. Haymond, 588 U.S. ___ (2019), is a case in which the U.S. Supreme Court struck down
's five-year mandatory minimum prison sentence for certain sex offenses committed by federal supervised releasees as unconstitutional unless the charges are proven to a jury beyond a reasonable doubt. Justices Ginsburg, Sotomayor, and Kagan joined Gorsuch's plurality opinion, while Breyer provided the necessary fifth vote with his narrow concurrence that began by saying he agreed with much of Justice Alito's dissent, which was joined by Justices Roberts, Thomas, and Kavanaugh.Mont v. United States, No. 17-8995, 587 U.S. ___ (2019), is a United States Supreme Court case concerning the proper interpretation of "supervised release" under 18 U.S.C. §3624(e). The case involved a prisoner who was convicted on drug distribution charges and was sentenced to imprisonment and supervised release. While on supervised release, he was charged and pleaded guilty to various state-law offenses, but due to administrative delays, his sentence was not entered until after the day on which his supervised release was to end. He was nonetheless charged with violating the terms of his supervised release, and he sought to challenge the court's jurisdiction to hear the case, arguing that his pretrial detention for the later offenses. The question in the case was whether a term of supervised release for one event can be tolled (paused) by imprisonment for another offense.