Adaucto Chavez-Meza pleaded guilty in 2013 to a methamphetamine-trafficking scheme. Though a federal judge initially handed down a 135-month sentence, which was at the lowest end of the guidelines range in effect at the time, Chavez-Meza requested modification of his sentence when the guidelines changed a year later.
Chavez-Meza’s sentence was reduced to 114 months but he was left guessing why the judge this time did not go to the lowest end of the new spectrum, 108 months.
With the judge having left blank a section for additional comments, the only record explaining the new sentence was a form that said the judge complied with federal law in considering certain factors when crafting the sentence.
The 10th Circuit likewise was silent in upholding the sentence, saying judges need not explain how they weighed the various factors they considered in crafting their sentences.
Chavez-Meza’s appeal led to embattled Deputy Attorney General Rod Rosenstein arguing before the U.S. Supreme Court for the first time in April, urging the justices to affirm. He said that judges are afforded deference when they check a box saying they considered all the necessary factors.
“The form reflects what the district court is required to do by statute,” Rosenstein said. “And so there’s no reason to presume here that the court is checking a box and not actually doing what’s required.”
Insisting that the decision is more involved than “merely a matter of checking a box,” Rosenstein said: “The court is actually making a conscious decision about what sentence to impose within that new guideline range.”
On Monday, the Supreme Court adopted Rosenstein’s position and ruled 5-3 that the record in Chavez-Meza’s case shows that the judge had a reasoned basis for his sentencing decision.
Justice Stephen Breyer delivered the majority’s opinion, noting that the same judge who initially sentenced Chavez-Meza was the one who issued his resentencing order and was familiar with the case record.
“The record as a whole strongly suggests that the judge originally believed that, given petitioner’s conduct, 135 months was an appropriately high sentence. So it is unsurprising that the judge considered a sentence somewhat higher than the bottom of the reduced range to be appropriate,” he wrote.
“This is not to say that a disproportionate sentence reduction never may require a more detailed explanation. It could be that, under different facts and a different record, the district court’s use of a barebones form order in response to a motion like petitioner’s would be inadequate,” Breyer continued. “But our task here is to decide the case before us. And given the simplicity of this case, the judge’s awareness of the arguments, his consideration of the relevant sentencing factors, and the intuitive reason why he picked a sentence above the very bottom of the new range, the judge’s explanation (minimal as it was) fell within the scope of the lawful professional judgment that the law confers upon the sentencing judge.” (Emphasis and parentheses in original.)
Chief Justice John Roberts and Justices Clarence Thomas, Ruth Bader Ginsburg and Samuel Alito joined Breyer in the majority.
Justice Anthony Kennedy penned a dissented opinion, and was joined by Justices Sonia Sotomayor and Elena Kagan.
Kennedy took issue with the lack of explanation for Chavez-Meza’s reduced sentence, saying the judge’s “reasons remain a mystery.”
“Under these circumstances, in my view the district court’s order was insufficient to allow for meaningful appellate review,” he wrote.
Kennedy continued, “The district court may well have had a legitimate reason for reducing Chavez-Meza’s sentence to 114 months instead of 108 months. And even a brief explanation stating that reason likely would have sufficed, for district courts need not write at length each time they rule upon a [resentencing] motion.”
Justice Neil Gorsuch, the high court’s newest member, took no part in the consideration or decision of the case.