Supreme Court rules judges cannot impose or lengthen prison terms for rehabilitation

[JURIST] The US Supreme Court [official website, JURIST news archive] Thursday ruled [opinion, PDF] in Tapia v. United States [Cornell LII Backgrounder] that a federal sentencing law does not permit sentencing judges to impose or lengthen prison terms for the purpose of fostering the defendant's rehabilitation. Alejandra Tapia was convicted of smuggling unauthorized aliens into the US, for which the guidelines recommended a sentence between 41 and 51 months. The judge for the US District Court for the Southern District of California sentenced Tapia to 51 months with the stated reason that the judge wanted the Tapia to facilitate the completion of the state's 500-hour drug abuse treatment program [RDAP fact sheet text]. The opinion of the court by Justice Elena Kagan held that 18 USC § 3582(a) [text] does not authorize a sentencing judge to impose a sentence in order for a defendant to take part in a rehabilitation program since the provision "recogniz[es] that imprisonment is not an appropriate means of promoting correction and rehabilitation." The court said that Congress passed the Sentencing Reform Act of 1989 in order to reduce the disparities in sentencing for similarly situated defendants when judges were left to their own "almost unfettered discretion." Thus, taken Congress's clear proscription to not consider rehabilitation it is improper for judges to take that into consideration. The court said:

We note first what we do not disapprove about Tapia’s sentencing. A court commits no error by discussing the opportunities for rehabilitation within prison or the benefits of specific treatment or training programs. To the contrary, a court properly may address a person who is about to begin a prison term about these important matters. ... So the sentencing court here did nothing wrong—and probably something very right—in trying to get Tapia into an effective drug treatment program. But the record indicates that the court may have done more—that it may have selected the length of the sentence to ensure that Tapia could complete the 500 Hour Drug Program. ... the court may have calculated the length of Tapia's sentence to ensure that she receive certain rehabilitative services. And that a sentencing court may not do.
Justice Sonia Sotormayor concurred, joined by Samuel Alito, agreeing with the court's holding but expressing reservations of whether the judge violated it. Sotomayor argued that the judge also properly relied on deterring further criminal behavior in imposing a sentence at the high end of the guidelines but ultimately agreed with the court saying, "I cannot be certain that he did not lengthen Tapia's sentence to promote rehabilitation in violation of §3582(a)."

The decision overturns the US Court of Appeals for the Ninth Circuit [official website], which held [opinion, PDF] that the trial judge made no error when basing Tapia's sentence on speculation that she could enter and complete the state's rehabilitation program. The US Court of Appeals for the Eighth Circuit [official website] has similarly held that a longer sentence to promote rehabilitation is permissible, but the US Courts of Appeals for the Second, Third, Eleventh and DC Circuits have held that it is prohibited [issue list, PDF].

 

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