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Concepcion v. United States

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Supreme Court of the United States
Concepcion v. United States
Term: 2021
Important Dates
Argued: January 19, 2022
Decided: June 27, 2022
Outcome
Reversed and remanded
Vote
5-4
Majority
Sonia Sotomayor • Clarence Thomas • Stephen Breyer • Elena Kagan • Neil Gorsuch
Dissenting
Brett Kavanaugh • Chief Justice John Roberts •Samuel Alito • Amy Coney Barrett

Concepcion v. United States is a case that was decided by the Supreme Court of the United States on June 27, 2022, during the court's October 2021-2022 term. The case was argued on January 19, 2022.

The court reversed the decision of the U.S. Court of Appeals for the 1st Circuit and remanded the case for further proceedings in a 5-4 ruling, holding that federal law allows district courts to consider changes in law or fact when considering a defendant's sentence reduction. Justice Sonia Sotomayor delivered the court's majority opinion. Justice Brett Kavanaugh filed a dissent, joined by Chief Justice John Roberts and Justices Samuel Alito and Amy Coney Barrett.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned sentencing requirements and reductions for drug offenses under the Fair Sentencing Act of 2010 and the First Step Act. Click here to learn more about the case's background.
  • The questions presented: "Whether, when deciding if it should "impose a reduced sentence" on an individual under Section 404(b) of the First Step Act of 2018, 21 U.S.C. § 841 note, a district court must or may consider intervening legal and factual developments."[2]
  • The outcome: The court reversed the decision of the U.S. Court of Appeals for the 1st Circuit and remanded the case for further proceedings.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 1st Circuit. To review the lower court's opinion, click here.[3]

    Timeline

    The following timeline details key events in this case:

    Background

    In 2008, petitioner Carlos Concepcion pleaded guilty to one count of possession of at least five grams of cocaine base, also known as crack cocaine, with intent to distribute and distribution. The U.S. District Court for the District of Massachusetts sentenced Concepcion to 19 years imprisonment, based on the 2008 edition of federal sentencing guidelines. In 2010, Congress passed the Fair Sentencing Act, reducing the sentencing penalties for most federal crimes involving cocaine base. In 2018, Congress passed the First Step Act, making the changes retroactive and authorizing federal courts to resentence offenders based on the new law. Concepcion asked the court to resentence him, based on these statutory changes. The District of Massachusetts denied the request.[3][4]

    On appeal to the U.S. Court of Appeals for the 1st Circuit, Concepcion argued that the district court was required to update and reevaluate its sentencing judgment in his case. The 1st Circuit denied his request and affirmed the District of Massachusetts' ruling, holding that the district court's sentencing judgment was reasonable and properly considered the pertinent factors of the case.[3]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether, when deciding if it should impose a reduced sentence" on an individual under Section 404(b) of the First Step Act of 2018, 21 U.S.C. § 841 note, a district court must or may consider intervening legal and factual developments.[5] ”

    Oral argument

    The U.S. Supreme Court heard oral argument on January 19, 2022.

    Audio

    Audio of oral argument:[6]



    Transcript

    Transcript of oral argument:[7]


    Outcome

    The court reversed the decision of the U.S. Court of Appeals for the 1st Circuit and remanded the case for further proceedings in a 5-4 ruling, holding that federal law allows district courts to consider changes in law or fact when considering a defendant's sentence reduction. Justice Sonia Sotomayor delivered the court's majority opinion. Justice Brett Kavanaugh filed a dissent, joined by Chief Justice John Roberts and Justices Samuel Alito and Amy Coney Barrett.[1]

    Opinion

    In the court's majority opinion, Justice Sotomayor wrote:[1]

    “ There is a longstanding tradition in American law, dating back to the dawn of the Republic, that a judge at sentencing considers the whole person before him or her “as an individual.” Koon v. United States, 518 U. S. 81, 113 (1996). In line with this history, federal courts today generally “exercise a wide discretion in the sources and types of evidence used” to craft appropriate sentences. Williams v. New York, 337 U. S. 241, 246 (1949). When a defendant appears for sentencing, the sentencing court considers the defendant on that day, not on the date of his offense or the date of his conviction. Pepper v. United States, 562 U. S. 476, 492 (2011). Similarly, when a defendant’s sentence is set aside on appeal, the district court at resentencing can (and in many cases, must) consider the defendant’s conduct and changes in the Federal Sentencing Guidelines since the original sentencing. Ibid.


    Congress enacted the First Step Act of 2018 against that backdrop. The First Step Act authorizes district courts to reduce the prison sentences of defendants convicted of certain offenses involving crack cocaine. The Act allows a district court to impose a reduced sentence “as if ” the revised penalties for crack cocaine enacted in the Fair Sentencing Act of 2010 were in effect at the time the offense was committed. The question in this case is whether a district court adjudicating a motion under the First Step Act may consider other intervening changes of law (such as changes to the Sentencing Guidelines) or changes of fact (such as behavior in prison) in adjudicating a First Step Act motion.

    The Court holds that they may. It is only when Congress or the Constitution limits the scope of information that a district court may consider in deciding whether, and to what extent, to modify a sentence, that a district court’s discretion to consider information is restrained. Nothing in the First Step Act contains such a limitation. Because district courts are always obligated to consider nonfrivolous arguments presented by the parties, the First Step Act requires district courts to consider intervening changes when parties raise them. By its terms, however, the First Step Act does not compel courts to exercise their discretion to reduce any sentence based on those arguments.[5]

    		”
    —Justice Sonia Sotomayor

    Dissenting opinion

    Justice Kavanaugh filed a dissenting opinion, joined by Chief Justice Roberts and Justices Alito and Barrett. In his dissent, Kavanaugh wrote:[1]

    “ The straightforward question in this case is whether district courts in First Step Act sentence-modification proceedings may reduce sentences based not only on the changes to the crack-cocaine sentencing ranges, but also on other unrelated legal or factual changes that have occurred since the original sentencing. For many crack-cocaine offenders who were sentenced before August 3, 2010, the most significant such change is a non-retroactive 2016 Sentencing Guidelines amendment that substantially altered the career-offender guideline and would significantly lower many of those offenders’ Guidelines ranges. See United States Sentencing Commission, Guidelines Manual, App. C, Amdt. 798 (Nov. 2021).


    The Court today concludes that district courts in First Step Act sentence-modification proceedings may reduce sentences based not only on the changes to the crack-cocaine sentencing ranges, but also on other unrelated legal or factual changes that have occurred since the original sentencing.

    I respectfully disagree. The text of the First Step Act authorizes district courts to reduce sentences based only on changes to the crack-cocaine sentencing ranges, not based on other unrelated changes that have occurred since the original sentencing.[5]

    		”
    —Justice Brett Kavanaugh

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[8]

    The court agreed to hear 68 cases during its 2021-2022 term.[9] Four cases were dismissed and one case was removed from the argument calendar.[10]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 U.S. Supreme Court, Concepcion v. United States, decided June 27, 2022
    2. ↑ 2.0 2.1 U.S. Supreme Court, "20-1650 CONCEPCION V. UNITED STATES: QUESTION PRESENTED:," accessed October 1, 2021
    3. ↑ 3.0 3.1 3.2 U.S. Court of Appeals for the 1st Circuit, United States v. Concepcion, decided March 15, 2021
    4. ↑ U.S. Supreme Court, "CARLOS CONCEPCION, PETITIONER, v. UNITED STATES OF AMERICA, RESPONDENT: ON PETITION FOR A WRIT OF CERTIORARI TO THE FIRST CIRCUIT," accessed October 4, 2021
    5. ↑ 5.0 5.1 5.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued January 19, 2022
    7. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued January 19, 2022
    8. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    9. ↑ Consolidated cases are counted as one case for purposes of this number.
    10. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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