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Holguin-Hernandez v. U.S.

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Supreme Court of the United States
Holguin-Hernandez v. U.S.
Term: 2019
Important Dates
Argument: December 10, 2019
Decided: February 26, 2020
Outcome
Vacated and remanded
Vote
9-0
Majority
Chief Justice John G. Roberts • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh
Concurring
Samuel Alito


Holguin-Hernandez v. U.S. is a case argued before the Supreme Court of the United States on December 10, 2019, during the court's October 2019-2020 term. The case came on a writ of certiorari to the United States Court of Appeals for the 5th Circuit.[1]

The court vacated and remanded the 5th Circuit's decision in a unanimous ruling, holding a formal objection after a sentencing pronouncement is not necessary to invoke "an appellate challenge to the substantive reasonableness of the sentence." Justice Breyer wrote, "A defendant who, by advocating for a particular sentence, communicates to the trial judge his view that a longer sentence is 'greater than necessary' has thereby informed the court of the legal error at issue in an appellate challenge to the substantive reasonableness of the sentence."[2] Click here for more information.

HIGHLIGHTS
  • The case: Holguin-Hernandez pleaded guilty to violating his supervised release by committing a new offense. The Western District of Texas revoked his term of supervised release and sentenced him to 12 months in prison to be served consecutively with the sentence from his new conviction. Holguin-Hernandez challenged his 12-month sentence as greater than necessary under 18 U.S.C. § 3553(a). On appeal, the 5th Circuit affirmed the district court's judgment.
  • The issue: Whether a formal objection after pronouncement of sentence is necessary to invoke appellate reasonableness review of the length of a defendant's sentence.[3]
  • The outcome: The court vacated and remanded the 5th Circuit's decision in a unanimous ruling, holding a formal objection after a sentencing pronouncement is not necessary to invoke "an appellate challenge to the substantive reasonableness of the sentence." Justice Breyer wrote, "A defendant who, by advocating for a particular sentence, communicates to the trial judge his view that a longer sentence is 'greater than necessary' has thereby informed the court of the legal error at issue in an appellate challenge to the substantive reasonableness of the sentence."[2]


    • You can review the lower court's opinion here.

    Timeline

    The following timeline details key events in this case:

    • February 26, 2020: The U.S. Supreme Court vacated and remanded the 5th Circuit's decision.
    • December 10, 2019: Oral argument
    • June 3, 2019: The U.S. Supreme Court agreed to hear the case.
    • January 22, 2019: Gonzalo Holguin-Hernandez, petitioner, filed a petition with the U.S. Supreme Court.
    • December 27, 2018: The 5th Circuit affirmed the ruling of the Western District of Texas.

    Background

    In 2016, Gonzalo Holguin-Hernandez was convicted of marijuana possession with the intent to distribute it. He was sentenced to 24 months of imprisonment and two years of supervised release. In November 2017, Holguin-Hernandez was arrested and again charged with marijuana possession with the intent to distribute it.[4]

    Holguin-Hernandez pleaded guilty to violating his supervised release by committing a new offense. The United States District Court for the Western District of Texas revoked his term of supervised release and sentenced him to 12 months in prison to be served consecutively with the sentence for his new conviction.[4][5]

    Holguin-Hernandez challenged his 12-month sentence as greater than necessary under 18 U.S.C. § 3553(a). 18 U.S.C. § 3553(a) provides that a "court shall impose a sentence sufficient, but not greater than necessary, to comply" with the seriousness of the offense. On December 27, 2018, the United States Court of Appeals for the 5th Circuit affirmed the district court's judgment, holding Holguin-Hernandez "failed to show that the imposition of the 12-month total sentence constituted a clear or obvious error" on the part of the district court.[5][6]

    Holguin-Hernandez petitioned the U.S. Supreme Court for review. In the petition, his attorney, Philip Lynch, asked whether Holguin-Hernandez's counsel needed to formally object to the 12-month sentence after it was announced "in order to obtain review of the sentence under the abuse-of-discretion, reasonableness standard this Court set out in Gall v. United States, 552 U.S. 38 (2007)." Lynch continued the circuit court of appeals were divided on the question.[4]

    Questions presented

    The petitioner presented the following questions to the court:

    Questions presented:
    • Whether a formal objection after pronouncement of sentence is necessary to invoke appellate reasonableness review of the length of a defendant's sentence.[3]

    Outcome

    In a unanimous opinion, the court vacated and remanded the judgment of the 5th Circuit Court of Appeals, holding a formal objection after a sentencing pronouncement is not necessary to invoke "an appellate challenge to the substantive reasonableness of the sentence."[2]

    Justice Stephen Breyer delivered the opinion of the court. Justice Samuel Alito filed a concurring opinion, joined by Justice Neil Gorsuch.

    Opinion

    In his opinion, Justice Breyer wrote:[2]

    “ A defendant who, by advocating for a particular sentence, communicates to the trial judge his view that a longer sentence is 'greater than necessary' has thereby informed the court of the legal error at issue in an appellate challenge to the substantive reasonableness of the sentence. He need not also refer to the standard of review.

    ...
    We hold only that the defendant here properly preserved the claim that his 12-month sentence was unreasonably long by advocating for a shorter sentence and thereby arguing, in effect, that this shorter sentence would have proved 'sufficient,' while a sentence of 12 months or longer would be 'greater than necessary' to 'comply with' the statutory purposes of punishment.[7]

    		”

    Breyer also noted that SCOTUS did not address other issues the government raised in the case.[2]

    Concurring opinion

    Justice Alito filed a concurring opinion, joined by Justice Gorsuch.

    In his concurring opinion, Justice Alito wrote that he agreed with the court but wanted "to emphasize what we are not deciding." Alito emphasized three points:[2]

    (1) "As we have previously explained, failing to object at all to a procedural error (e.g., a district court’s miscalculation of the Guidelines range) will subject a procedural challenge to plain-error review."

    (2) "We do not suggest that a generalized argument in favor of less imprisonment will insulate all arguments regarding the length of a sentence from plain-error review."

    (3) "We do not decide whether this petitioner properly preserved his particular substantive-reasonableness arguments, namely, that he did not pose a danger to the public and that a 12-month sentence would not serve deterrence purposes."

    Text of the opinion

    Read the full opinion here.

    Oral argument

    Audio

    Audio of oral argument:[8]



    Transcript

    See also

    External links

    Footnotes

    1. ↑ SCOTUSblog, "Holguin-Hernandez v. United States," accessed June 6, 2019
    2. ↑ 2.0 2.1 2.2 2.3 2.4 2.5 Supreme Court of the United States, Holguin-Hernandez v. U.S., decided February 26, 2020
    3. ↑ 3.0 3.1 Supreme Court of the United States, "Questions presented: 18-7739 Holguin-Hernandez v. United States," accessed June 6, 2019
    4. ↑ 4.0 4.1 4.2 Supreme Court of the United States, "Petition for writ of certiorari to the United States Court of Appeals for the Fifth Circuit," accessed June 6, 2019
    5. ↑ 5.0 5.1 United States Court of Appeals for the 5th Circuit, U.S. v. Holguin-Hernandez, December 27, 2018
    6. ↑ Legal Information Institute, "18 U.S. Code § 3553. Imposition of a sentence," accessed June 6, 2019
    7. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    8. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed December 16, 2019
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