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Martha Daughtrey

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Martha Daughtrey
Image of Martha Daughtrey

Nonpartisan

United States Court of Appeals for the 6th Circuit (senior status)
Tenure

2009 - Present

Years in position

16

Prior offices
United States Court of Appeals for the 6th Circuit

Education

Bachelor's

Vanderbilt University, 1964

Law

Vanderbilt University Law School, 1968

Personal
Birthplace
Covington, Ky.


Martha Craig Daughtrey is a federal judge on senior status with the United States Court of Appeals for the 6th Circuit. She joined the court in 1993 after being nominated by President Bill Clinton.[1]

Education

A native of Covington, Kentucky, Daughtrey graduated from Vanderbilt University with her bachelor's degree in 1964 and from Vanderbilt University Law School with her J.D. in 1968.[1]

Professional career

  • 2009-present: Senior judge
  • 1993-2009: Judge
  • 1975-1982: Lecturer
  • 1972-1975: Assistant professor

Judicial career

Sixth Circuit Court of Appeals

Nomination Tracker
Fedbadgesmall.png
Nominee Information
Name: Martha Craig Daughtrey
Court: United States Court of Appeals for the 6th Circuit
Progress
Confirmed 106 days after nomination.
ApprovedANominated: August 6, 1993
ApprovedAABA Rating: Unanimously Well Qualified
Questionnaire:
ApprovedAHearing: October 20, 1993
QFRs: (Hover over QFRs to read more)
ApprovedAReported: November 18, 1993 
ApprovedAConfirmed: November 20, 1993
ApprovedAVote: Voice vote

Daughtrey was nominated to the United States Court of Appeals for the 6th Circuit by President Bill Clinton on August 6, 1993, to a new seat created by 104 Stat. 5089. The American Bar Association rated Daughtrey Unanimously Well Qualified for the nomination.[2] Hearings on Daughtrey's nomination were held before the United States Senate Committee on the Judiciary on October 20, 1993, and her nomination was reported by then-U.S. Sen. Joseph Biden (D-Del.) on November 18, 1993. Daughtrey was confirmed on a voice vote of the U.S. Senate on November 20, 1993, and she receiver her commission on November 22, 1993. She assumed senior status on January 1, 2009.[1][3] She was succeeded in this position by Judge Jane Stranch.

Noteworthy cases

Federal judges arrive at disparate conclusions regarding Auer deference and agency guidance (2018)

On October 22, 2018, a three-judge panel of the United States Court of Appeals for the 6th Circuit issued dissimilar conclusions in U.S. v. Havis that either challenged or upheld the use of Auer deference—a deference principle in which a federal court defers to an agency's interpretation of an ambiguous rule promulgated by the agency.[4][5]

The case involves the sentencing of Jeffrey Havis on a firearms charge in Tennessee. The United States Sentencing Commission increased Havis’ base sentence due to a prior conviction for attempting to deliver cocaine. Havis argued that the commission’s sentencing guidelines only call for enhanced sentences in the case of a completed drug transfer. The sentencing guidelines for attempted transfers are only featured in the agency’s commentary on sentencing guidelines and, Havis claimed, are not entitled to Auer deference.[4][5]

Commentary is a form of agency guidance—documents created by government agencies to explain, interpret, or advise interested parties about rules, laws, and procedures. Guidance documents clarify and affect how agencies administer regulations and programs. However, they are not legally binding in the same way as rules issued through one of the rulemaking processes of the Administrative Procedure Act (APA).[4][5]

The Sixth Circuit upheld Havis’ sentence due to precedent in the 2012 case U.S. v. Evans, which held that the sentencing guidelines include attempts to sell or distribute drugs. However, all three judges on the panel—Amul Thapar, Jane Stranch, and Martha Daughtrey—agreed that the 2012 court may have reached the incorrect conclusion by treating agency guidance as binding. In order to overturn precedent, Thapar and Stranch agreed that the case would need to be heard by the Sixth Circuit en banc or by the United States Supreme Court. Daughtrey dissented and argued that U.S. v. Evans was not controlling precedent because the case did not address Havis' concerns regarding the separation of powers.[4][5]

Thapar criticized Auer deference in his concurrence, arguing that the deference principle violates the separation of powers by calling for federal courts to yield to agency interpretations of their own rules. "How is it fair in a court of justice for judges to defer to one of the litigants?” questioned Thapar. "In essence, the argument boils down to this—the government is populated by experts and when they speak we should tip the scales of justice in their favor. Such deference is found nowhere in the Constitution—the document to which judges take an oath.”[4][5]

Stranch, on the other hand, defended Auer deference in her concurrence. She argued that “[t]he current arguments for curtailing agency deference risk dismissing a system that Congress created out of a need to employ the significant expertise held by agencies and their stakeholders in complex areas of the law and instead substituting courts that are ill-equipped for the task.”[4][5]

Should Havis seek further review, the case would be reheard by the full Sixth Circuit.[4][5]

Same-sex marriage ban upheld in Sixth Circuit (2014)
See also: United States Court of Appeals for the 6th Circuit (DeBoer, et al v. Snyder, et al, Case 2:12-cv-10285)

Judge Jeffrey Sutton was the opinion writing judge in DeBoer et al v. Snyder, et al, a case upholding the bans on same-sex marriage in Michigan, Ohio, Kentucky and Tennessee. In the court's opinion upholding the ban, Sutton based the reversal on allowing states the ability to govern themselves through the democratic process without the fear of a select few judges overruling a decision made by the majority. Sutton stated in his conclusion:

“ Better in this instance, we think, to allow change through the customary political process, in which the people, gay and straight alike, become the heroes of their own stories by meeting each other not as adversaries in a court system but as fellow citizens seeking to resolve a new social issue in a fair-minded way.[6][7] ”

Judge Deborah Cook joined Sutton's opinion.[8]

The dissenting opinion in the 2-1 ruling was written by Martha Daughtrey. She expressed that the three branches of government are equal, and the legislative branch should not be given higher authority over the judicial branch. In her counterargument, Daughtrey stated:

“ Today, my colleagues seem to have fallen prey to the misguided notion that the intent of the framers of the United States Constitution can be effectuated only by cleaving to the legislative will and ignoring and demonizing an independent judiciary. Of course, the framers presciently recognized that two of the three co-equal branches of government were representative in nature and necessarily would be guided by self-interest and the pull of popular opinion. To restrain those natural, human impulses, the framers crafted Article III to ensure that rights, liberties, and duties need not be held hostage by popular whims.[6][7] ”

See also

External links

Footnotes

  1. ↑ 1.0 1.1 1.2 1.3 Federal Judicial Center, "Biographical directory of federal judges," accessed November 28, 2016
  2. ↑ American Bar Association, "Ratings of Article III judicial nominees, 103rd Congress," accessed November 28, 2016
  3. ↑ United States Congress, "PN 532 — Martha Craig Daughtrey — The Judiciary," accessed November 28, 2016
  4. ↑ 4.0 4.1 4.2 4.3 4.4 4.5 4.6 Reuters, "6th Circuit judge (and SCOTUS short-lister) calls for end to Auer deference," October 23, 2018
  5. ↑ 5.0 5.1 5.2 5.3 5.4 5.5 5.6 Reason, "Three Judges, Four Opinions, and a Debate on Auer Deference," October 23, 2018
  6. ↑ 6.0 6.1 U.S.Court of Appeals for the Sixth Circuit, DeBoer v. Snyder, November 6, 2014
  7. ↑ 7.0 7.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
  8. ↑ SCOTUSBlog.com, "Sixth Circuit: Now, a split on same-sex marriage," November 6, 2014
Political offices
Preceded by:
NA-New Seat
104 Stat. 5089 		Sixth Circuit Court of Appeals
1993–2009 		Succeeded by:
Jane Stranch



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