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United States v. Haymond

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Supreme Court of the United States
United States v. Haymond
Term: 2018
Important Dates
Argument: February 26, 2019
Decided: June 26, 2019
Outcome
Vacated and remanded
Vote
5-4
Majority
Ruth Bader Ginsburg • Sonia Sotomayor • Elena Kagan • Neil Gorsuch
Concurring
Stephen Breyer
Dissenting
Samuel Alito • Chief Justice John G. Roberts • Clarence Thomas • Brett Kavanaugh


United States v. Haymond is a case argued before the Supreme Court of the United States on February 26, 2019, during the court's 2018-2019 term. The case came on a writ of certiorari to the United States Court of Appeals for the 10th Circuit.[1]

On June 26, 2019, the U.S. Supreme Court issued a 5-4 opinion that vacated and remanded the 10th Circuit's judgment. Justice Neil Gorsuch wrote the majority opinion. Justice Stephen Breyer concurred in judgment. Justice Samuel Alito filed a dissenting opinion, in which Chief Justice John Roberts and Justices Clarence Thomas and Brett Kavanaugh joined. Click here for more information about the opinion.

HIGHLIGHTS
  • The case: Andre Ralph Haymond was convicted of possession and attempted possession of child pornography in 2010. He was on supervised release in 2015 when probation officers seized a phone and four computers during a surprise search of his apartment. Following a forensic search of the devices, officers found that Haymond had committed five violations of the conditions of his supervised release. Haymond was sentenced to five years in jail. Haymond appealed, arguing that the court did not have sufficient evidence to convict him of one of the five violations and that he had been deprived of due process.
  • The issue: Whether the court of appeals erred in holding "unconstitutional and unenforceable" the portions of 18 U.S.C. 3583(k) that required the district court to revoke respondent's ten-year term of supervised release, and to impose five years of reimprisonment, following its finding by a preponderance of the evidence that respondent violated the conditions of his release by knowingly possessing child pornography.[2]
  • The outcome: On June 26, 2019, the U.S. Supreme Court issued a 5-4 opinion that vacated and remanded the 10th Circuit's judgment, holding federal law violated Haymond's Fifth and Sixth Amendment rights.[3]


    • You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    • June 26, 2019: The U.S. Supreme Court vacated and remanded the 10th Circuit's judgment.
    • February 26, 2019: Oral argument
    • October 26, 2018: U.S. Supreme Court agreed to hear case
    • June 15, 2018: Petition filed with U.S. Supreme Court
    • August 31, 2017: The Tenth Circuit Court affirmed the lower court's revocation of Haymond's supervised release, but vacated his sentence and remanded the case for resentencing.

    Background

    Andre Ralph Haymond was convicted of possession and attempted possession of child pornography in 2010. He was sentenced to 38 months in jail and 10 years of supervised release. He was on supervised release in 2015 when probation officers seized a phone and four computers during a surprise search of his apartment. During a forensic search of the devices, officers found web history containing websites names indicating sexually explicit material. They also found 59 images of child pornography.[5]

    Haymond's probation officer alleged that he had committed five violations of the conditions of his supervised release:[4]

    “
    • possession of fifty-nine images of child pornography, in violation of the mandatory condition that Haymond not commit another federal, state, or local crime;
    • failure to disclose to the probation office all internet devices he possessed, in violation of a special computer restriction;
    • possession of numerous sexually explicit images on his phone, in violation of a special condition that he not view or possess pornography;
    • failure to install and pay for computer monitoring software, in violation of a special monitoring condition; and
    • failure to attend sex offender treatment on fifteen occasions, in violation of a special condition that he participate in treatment[6]
    		 ”

    In accordance with 18 U.S.C.§ 3583(k), which requires a mandatory minimum sentence of five years for the possession of child pornography for those on supervised release from a crime involving a minor, Haymond was sentenced to five years in jail followed by five years of supervised release. Haymond appealed, arguing that the presence of images in a phone's cache was not sufficient evidence to prove that he had knowingly possessed child pornography. He also argued that 18 U.S.C.§ 3583(k) was unconstitutional because it denied him of due process.[4]

    The 10th Circuit Court agreed with the lower court in that there was sufficient evidence of Haymond's violations of his supervised release. It vacated Haymond's sentence, however, and remanded the case for resentencing because it agreed that 18 U.S.C.§ 3583(k) was unconstitutional. The ruling stated, "we agree that 18 U.S.C. § 3583(k) is unconstitutional because it strips the sentencing judge of discretion to impose punishment within the statutorily prescribed range, and it imposes heightened punishment on sex offenders based, not on their original crimes of conviction, but on new conduct for which they have not been convicted by a jury beyond a reasonable doubt."[4]

    The federal government appealed the case to the U.S. Supreme Court, which agreed to hear the case on October 26, 2018.

    Questions presented

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

    Questions presented:
    • Whether the court of appeals erred in holding "unconstitutional and unenforceable" the portions of 18 U.S.C. 3583(k) that required the district court to revoke respondent's ten-year term of supervised release, and to impose five years of reimprisonment, following its finding by a preponderance of the evidence that respondent violated the conditions of his release by knowingly possessing child pornography.

    Outcome

    On June 26, 2019, the U.S. Supreme Court issued a 5-4 opinion that vacated and remanded the 10th Circuit's judgment, holding federal law violated Haymond's Fifth and Sixth Amendment rights.[3]

    Justice Neil Gorsuch wrote the majority opinion. Justice Stephen Breyer concurred in judgment. Justice Samuel Alito filed a dissenting opinion, in which Chief Justice John Roberts and Justices Clarence Thomas and Brett Kavanaugh joined.

    Opinion

    In his opinion, Justice Gorsuch wrote:[3]

    “ Only a jury, acting on proof beyond a reasonable doubt, may take a person’s liberty. ... Yet in this case a congressional statute compelled a federal judge to send a man to prison for a minimum of five years without empaneling a jury of his peers or requiring the government to prove his guilt beyond a reasonable doubt. As applied here, we do not hesitate to hold that the statute violates the Fifth and

    Sixth Amendments. [6]

    		”

    Concurring opinion

    Justice Breyer filed an opinion concurring in judgment.

    In his concurring opinion, Justice Breyer wrote:[3]

    “ I agree with much of the dissent, in particular that the role of the judge in a supervised-release proceeding is consistent with traditional parole. ... Nevertheless, I agree with the plurality that this specific provision of the supervised-release statute, §3583(k), is unconstitutional. ... In particular, three aspects of this provision, considered in combination, lead me to think it is less like ordinary revocation and more like punishment for a new offense, to which the jury right would typically attach. [6] ”

    Dissenting opinion

    Justice Alito filed a dissenting opinion, in which Chief Justice Roberts and Justices Thomas and Kavanaugh joined.

    In his dissent, Justice Alito wrote:[3]

    “ I do not think that there is a constitutional basis for today’s holding, which is set out in JUSTICE BREYER’s opinion, but it is narrow and has saved our jurisprudence from the consequences of the plurality opinion, which is not based on the original meaning of the Sixth Amendment, is irreconcilable with precedent, and sports rhetoric with potentially revolutionary implications.[6] ”

    Text of the opinion

    Read the full opinion here.

    Audio



    Transcript

    See also

    External links

    Footnotes

    1. ↑ Supreme Court of the United States, "17-1672 United States v. Haymond," accessed November 21, 2018
    2. ↑ 2.0 2.1 Supreme Court of the United States, "QPReport 17-1672 United States v. Haymond," accessed November 21, 2018
    3. ↑ 3.0 3.1 3.2 3.3 3.4 Supreme Court of the United States, United States v. Haymond, decided June 26, 2019
    4. ↑ 4.0 4.1 4.2 4.3 SCOTUSblog, "United States v. Haymond," accessed November 21, 2018
    5. ↑ Oyez, "United States v. Haymond," accessed November 21, 2018
    6. ↑ 6.0 6.1 6.2 6.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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