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Hughes v. United States

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Supreme Court of the United States
Hughes v. United States
Term: 2017
Important Dates
Argument: March 27, 2018
Decided: June 4, 2018
Outcome
Eleventh Circuit reversed
Vote
6 - 3
Majority
Anthony Kennedy • Ruth Bader Ginsburg • Stephen Breyer • Sonia Sotomayor • Elena Kagan • Neil Gorsuch
Concurring
Sonia Sotomayor
Dissenting
Chief Justice John G. Roberts • Clarence Thomas • Samuel Alito


Hughes v. United States is a case argued during the October 2017 term of the U.S. Supreme Court. Argument in the case was held on March 27, 2018. The case came on a writ of certiorari to the United States Court of Appeals for the 11th Circuit.

HIGHLIGHTS
  • The case: Erik Hughes pleaded guilty to two criminal counts. His plea agreement dictated that he would be sentenced to 180 months' imprisonment. After he entered his guilty plea, the U.S. Sentencing Commission retroactively reduced the Sentencing Guidelines range for the crimes to which he had pleaded guilty. Hughes moved for a reduction in his sentence. The district court dismissed his request, ruling that under Freeman v. United States, Hughes was not entitled to a sentencing reduction because his original sentence had not been based on the Sentencing Guidelines. On appeal, the United States Court of Appeals for the 11th Circuit affirmed.
  • The issue: "Whether, as the four-Justice plurality in Freeman concluded, a defendant who enters into a Fed. R. Crim. P. 11(c)(1)(C) plea agreement is generally eligible for a sentence reduction if there is a later, retroactive amendment to the relevant Sentencing Guidelines range."[1]
  • The outcome: The Supreme Court voted 6 - 3 to reverse the Eleventh Circuit's ruling.[2]


    • You can review the lower court's opinion here.[3]

    Background

    Legal question

    This was a case about the intersection of two United States Supreme Court cases. It was also about the extent to which a defendant who enters into a plea deal is eligible for a reduction in his or her sentence if the United States Sentencing Commission retroactively reduces the sentencing range applicable to that defendant's crimes.[3]

    The two cases at issue were Marks v. United States and Freeman v. United States. It takes a majority of justices (five) to issue a judgment. Sometimes, five justices agree on the outcome of a case but do not agree on the reasoning underlying the outcome. Three or four justices may join what is called a plurality opinion--the opinion that is joined by more justices than any other single opinion but not by enough justices to constitute a majority--and one or two other justices may write or join opinions concurring in the judgment but not in the plurality's reasoning. In Marks, the U.S. Supreme Court explained, "When a fragmented Court decides a case and no single rationale explaining the result enjoys the assent of five Justices, the holding of the Court may be viewed as that position taken by those Members who concurred in the judgments on the narrowest grounds."[4] In other words, if four justices join a plurality opinion and one justice concurs in the judgment by writing a separate opinion based on different reasoning, the court's holding is limited to the narrowest grounds that the opinions share.[1][3]

    Freeman is a case about the effect of retroactively reduced Sentencing Guidelines on the sentences of defendants who had previously pleaded guilty. Four justices joined a plurality opinion concluding that defendants who had accepted plea agreements were entitled to reduced sentences if the applicable Guidelines were retroactively reduced. Justice Sonia Sotomayor concurred in the judgment in the case but wrote separately to identify the circumstances under which she believed defendants who had accepted plea agreements would be eligible for sentencing reductions.[3]

    The interpretation of Freeman was also at issue in another of this term's cases. See Koons v. United States.

    Case background

    Erik Hughes was sentenced to 180 months' imprisonment after accepting a guilty plea agreement. The district court calculated Hughes' sentencing range under the United States Sentencing Guidelines to be 188 to 235 months but entered a 180-month sentence for Hughes under the terms of the plea agreement. The United States Court of Appeals for the 11th Circuit explained:

    “ Just over a year later, Hughes filed a motion to reduce his sentence, 18 U.S.C. § 3582(c)(2). Section 3582(c)(2) allows a court to reduce the term of imprisonment of 'a defendant who has been sentenced . . . based on a sentencing range that has subsequently been lowered by the Sentencing Commission.' Hughes sought a reduction based on Amendment 782 to the Sentencing Guidelines, which reduced the offense levels for certain drug offenses by two levels and applies retroactively. According to Hughes, applying the amendment would reduce his Guidelines range to 151 to 188 months [3][5] ”


    Citing Justice Sotomayor's concurring decision in Freeman, the district court denied Hughes' motion. Hughes then appealed to the 11th Circuit.[3]

    Panel opinion

    On appeal, a panel of the United States Court of Appeals for the 11th Circuit affirmed the district court's denial of Hughes' motion to reduce his sentence. The court first explained its view of the holdings in Freeman:

    “ Five justices agreed that the district court could reduce Freeman’s sentence, but those justices differed in their reasoning. The plurality opinion, joined by four justices, determined that the '[t]he district judge’s decision to impose a sentence may . . . be based on the Guidelines even if the defendant agrees to plead guilty under Rule 11(c)(1)(C).' [The plurality continued,] 'In every case the judge must exercise discretion to impose an appropriate sentence' and '[t]his discretion, in turn, is framed by the Guidelines.' But Justice Sotomayor concurred only in the judgment.


    Justice Sotomayor’s concurring opinion determined that 'the term of imprisonment imposed by a district court pursuant to an agreement authorized by Federal Rule of Criminal Procedure 11(c)(1)(C) . . . is based on the agreement itself, not on the judge’s calculation of the Sentencing Guidelines.' Under this view, if a plea agreement 'call[s] for the defendant to be sentenced within a particular Guidelines sentencing range,' the acceptance of the agreement by the district court 'obligates the court to sentence the defendant accordingly, and there can be no doubt that the term of imprisonment the court imposes is ‘based on’ the agreed-upon sentencing range.' And if a plea agreement “provide[s] for a specific term of imprisonment . . . but also make[s] clear that the basis for the specified term is a Guidelines sentencing range applicable to the offense to which the defendant pleaded guilty,' then '[a]s long as that sentencing range is evident from the agreement itself,' the term of imprisonment imposed is 'based on' that range.[3][6][5]

    		”

    The court concluded that Sotomayor had outlined two circumstances in which a defendant would be eligible for a retroactive sentencing reduction after a guilty plea: 1) when the plea agreement called for sentencing within a particular Guidelines range; or 2) where the agreement gives a specific term of imprisonment "but also make[s] clear that the basis for the specified term is a Guidelines sentencing range." The court ruled that Sotomayor's concurrence carved out two specific situations from the broad application identified by the plurality. Therefore, citing Marks, the court concluded that Sotomayor's reasoning was the holding of the court in Freeman because it was the narrowest reasoning offered by a justice who concurred in the judgment.[3]

    Applying its conclusions to Hughes' case, the court ruled that Hughes' plea agreement did not call for sentencing within a particular Guidelines range, nor did it make clear that the basis for the specified sentence of 180 months was a Guidelines sentencing range. Therefore, the court ruled, Hughes was not eligible for a sentencing reduction under Freeman.[3]

    Petitioner's challenge

    The petitioner, Hughes, challenged the holding of the United States Court of Appeals for the 11th Circuit. Hughes argued that the Eleventh Circuit erred in concluding that Freeman did not entitle him to a sentencing reduction.[3]

    Certiorari granted

    On July 27, 2017, the petitioner initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the United States Court of Appeals for the 11th Circuit. The U.S. Supreme Court granted the petitioner's request for certiorari on December 8, 2017. Argument in the case was held on March 27, 2018.[1]

    Question presented

    Question presented:

    "This Court explained in Marks v. United States, 430 U.S. 188, 193 (1977), that '[w]hen a fragmented Court decides a case and no single rationale explaining the result enjoys the assent of five Justices, "the holding of the Court may be viewed as that position taken by those Members who concurred in the judgments on the narrowest grounds."' In Freeman v. United States, 564 U.S. 522 (2011), the Court issued a fractured 4-1-4 decision concluding that a defendant who enters into a plea agreement under Fed. R. Crim. P. 11(c)(1)(C) may be eligible for a reduction in his sentence if the Sentencing Commission subsequently issues a retroactive amendment to the Sentencing Guidelines. But the four-Justice plurality and Justice Sotomayor's concurrence shared no common rationale and the courts of appeals have divided over how to apply Freeman's result. The questions presented are:
    1. Whether this Court's decision in Marks means that the concurring opinion in a 4-1-4 decision represents the holding of the Court where neither the plurality's reasoning nor the concurrence's reasoning is a logical subset of the other.
    2.Whether, under Marks, the lower courts are bound by the four-Justice plurality opinion in Freeman, or, instead, by Justice Sotomayor's separate concurring opinion with which all eight other Justices disagreed.
    3. Whether, as the four-Justice plurality in Freeman concluded, a defendant who enters into a Fed. R. Crim. P. 11(c)(1)(C) plea agreement is generally eligible for a sentence reduction if there is a later, retroactive amendment to the relevant Sentencing Guidelines range."[1]

    Audio

    • Audio of oral argument:[7]



    Transcript

    • Transcript of oral argument:[8]

    Outcome

    Decision

    On a vote of 6 - 3, the Supreme Court reversed the ruling of the Eleventh Circuit.[2]

    Majority opinion

    Justice Anthony Kennedy authored the opinion for the court, joined by Justices Stephen Breyer, Ruth Bader Ginsburg, Sonia Sotomayor, Elena Kagan, and Neil Gorsuch.

    Kennedy discussed the intersection of Freeman and Marks and emphasized that "this Court’s precedents since Freeman have further confirmed that the Guidelines remain the foundation of federal sentencing decisions." There are narrow exceptions, he wrote, as in the case of Koons v. United States. But generally, he continued, "a defendant's sentence will be 'based on' his Guidelines range." Because the Guidelines "are a district court's starting point," it followed that "when the Commission lowers a defendant's Guidelines range the defendant will be eligible for relief . . . absent clear demonstration, based on the record as a whole, that the court would have imposed the same sentence regardless of the Guidelines."[2]

    In this case, Kennedy continued, "the District Court accepted Hughes’ Type-C agreement after concluding that a 180-month sentence was consistent with the Sentencing Guidelines" and "imposed a sentence that the court deemed 'compatible' with the Guidelines."[2]

    “ Thus, the sentencing range was a basis for the sentence that the District Court imposed. That range has 'subsequently been lowered by the Sentencing Commission,' so Hughes is eligible for relief under §3582(c)(2). The Court expresses no view as to whether the District Court should exercise its discretion to reduce Hughes’ sentence after considering the §3553(a) factors and the Commission’s relevant policy statements. See 18 U. S. C. §3582(c)(2).[2][5] ”


    Concurrence by Justice Sotomayor

    Justice Sonia Sotomayor joined the majority opinion in full and also wrote separately. Sotomayor discussed the confusion caused by the Freeman plurality opinion and her concurring opinion. Given the confusion the split opinion had caused, she concluded, "I therefore join the majority in full because doing so helps to ensure clarity and stability in the law and promotes uniformity in sentencing imposed by different federal courts for similar criminal conduct."[2]

    Dissent by Chief Justice Roberts

    Chief Justice John Roberts dissented from the majority's ruling, joined by Justices Clarence Thomas and Samuel Alito.[2]

    Roberts, who had also dissented in Freeman, referenced his Freeman dissent to reiterate the arguments he had made in that case. He argued that when the defendant and the prosecutor agree to a plea, the district court does not have discretion to change the term of imprisonment based on the Guidelines; the court is only empowered to accept or reject the agreement.[2]

    “ As the Court points out, a district court considering whether to accept a Type-C agreement must consult the Guidelines, as the District Court did here. But 'when determining the sentence to impose,' the district court may base its decision on one thing and one thing only—the plea agreement. The Court characterizes this distinction as 'artificial,' arguing that the district court’s ultimate imposition of a sentence often has as much to do with its Guidelines calculation as anything else. But that is not so: With a Type-C agreement, the sentence is set by the parties, not by a judge applying the Guidelines . . . To hold otherwise would be to contravene the very purpose of (C) agreements—to bind the district court and allow the Government and the defendant to determine what sentence he will receive.[2][5] ”


    Text of the opinion

    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 Supreme Court of the United States, "Hughes v. United States" Question Presented, December 8, 2017
    2. ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 United States Supreme Court, "Hughes v. United States opinion," June 4, 2018
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 United States Court of Appeals for the 11th Circuit, "Hughes v. United States" Opinion, February 27, 2017
    4. ↑ Internal quotations omitted.
    5. ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Internal citations omitted.
    7. ↑ Supreme Court of the United States, Hughes v. United States, argued March 27, 2018
    8. ↑ Supreme Court of the United States, Hughes v. United States, argued March 27, 2018
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