Tapia v. United States
Encyclopedia
Tapia v. United States, No. 10-5400
(2011), was a case in which United States Supreme Court held that a federal court cannot give a criminal defendant a longer sentence
to promote rehabilitation
.
Tapia petitioned the Supreme Court for certiorari
, citing the circuit split
on the issue. Specifically, the Eighth and Ninth Circuits permit the use of rehabilitation as a factor in sentencing, while four other circuit courts prohibit it. The Court agreed to hear the case on that issue.
precludes a federal court from imposing or lengthening a prison term for the purposes of prompting rehabilitation. The Court held in a unanimous opinion that it does. First considered by the Court was the language of the Sentencing Reform Act
, specifically that a court must "recogniz[e] that imprisonment is not an appropriate means of promoting correction and rehabilitation." Further, the act instructs the courts to acknowledge this fact when "determining whether to impose a term of imprisonment, and... [when] determining the length of the term."
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2011), was a case in which United States Supreme Court held that a federal court cannot give a criminal defendant a longer sentence
Sentence (law)
In law, a sentence forms the final explicit act of a judge-ruled process, and also the symbolic principal act connected to his function. The sentence can generally involve a decree of imprisonment, a fine and/or other punishments against a defendant convicted of a crime...
to promote rehabilitation
Rehabilitation (penology)
Rehabilitation means; To restore to useful life, as through therapy and education or To restore to good condition, operation, or capacity....
.
Background
Alejandra Tapia was sentenced to 51 months in federal prison for bringing an illegal immigrant into the United States for financial gain. Tapia challenged the basis for the District Court's sentencing decision. Specifically, Tapia challenged basing the length of sentence on speculation about when Tapia would be able to enter and complete the Bureau of Prisons' drug abuse treatment program. In a brief order, the Ninth Circuit Court of Appeals, relying on its previous decisions, affirmed the decision.Tapia petitioned the Supreme Court for certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
, citing the circuit split
Circuit split
In the context of United States federal courts, a circuit split exists when two or more circuits in the United States court of appeals system have different interpretations of federal law....
on the issue. Specifically, the Eighth and Ninth Circuits permit the use of rehabilitation as a factor in sentencing, while four other circuit courts prohibit it. The Court agreed to hear the case on that issue.
Opinion of the Court
The issue before the Court was whether the Sentencing Reform ActSentencing Reform Act
The Sentencing Reform Act, part of the Comprehensive Crime Control Act of 1984, was a U.S. federal statute intended to increase consistency in United States federal sentencing. It established the United States Sentencing Commission. It also abolished federal parole.The act was passed by large...
precludes a federal court from imposing or lengthening a prison term for the purposes of prompting rehabilitation. The Court held in a unanimous opinion that it does. First considered by the Court was the language of the Sentencing Reform Act
Sentencing Reform Act
The Sentencing Reform Act, part of the Comprehensive Crime Control Act of 1984, was a U.S. federal statute intended to increase consistency in United States federal sentencing. It established the United States Sentencing Commission. It also abolished federal parole.The act was passed by large...
, specifically that a court must "recogniz[e] that imprisonment is not an appropriate means of promoting correction and rehabilitation." Further, the act instructs the courts to acknowledge this fact when "determining whether to impose a term of imprisonment, and... [when] determining the length of the term."
Concurrence
Justice Sotomayor wrote a concurring opinion, joined by Justice Alito, in which she expressed "skepticism that the District Judge [had actually] violated this proscription in this case".External links
- Tapia v. United States coverage on SCOTUSblogSCOTUSblogSCOTUSblog is a law blog written by lawyers and law students about the Supreme Court of the United States . The blog is sponsored by Bloomberg Law. The blog's first post occurred October 1, 2002. The blog moved to its current address on February 7, 2005. In the same year, it was featured by...