The US Supreme Court [official website] ruled [opinion, PDF] Monday that a court’s mistake in calculating a sentence under the advisory US Sentencing Guidelines [manual] should result in relief for the defendant, even if the original sentence was within the federal guidelines. This decision reversed and remanded the the lower court’s ruling.

In Rosales-Mireles v. United States, one of the defendant’s prior convictions was mistakenly counted twice. The defendant’s sentence was close to the bottom of the incorrect range but around the middle of the correct range.

According to the formula of plain-error review, in order for the defendant to be entitled [SCOTUSblog report] to relief “(1) there must be an error that has not been intentionally relinquished or abandoned; (2) the error must be plain…; and (3) the error must have affected the defendant’s substantial rights.” To meet the fourth prong, the error must also “‘seriously affect[] the fairness, integrity or public reputation of judicial proceedings.'”

Writing for the seven justice majority, Justice Sonia Sotomayor said that the error met the fourth prong. “In broad strokes, the public legitimacy of our justice system relies on procedures that are ‘neutral, accurate, consistent, trustworthy, and fair,’ and that ‘provide opportunities for error correction.'”

Sotomayor also wrote that the US Court of Appeals for the Fifth Circuit had improperly used the “shock the conscience” test in determining whether the defendant should be re-sentenced.

Even though the sentence given was within the correct range, the majority ruled, “Before a court of appeals can consider the substantive reasonableness of a sentence, ‘[i]t must first ensure that the district court committed no significant procedural error, such as failing to calculate (or improperly calculating) the Guidelines range.'”
Justice Clarence Thomas, wrote in his dissent joined by Justice Samuel Alito, “This Court has repeatedly concluded that purely procedural errors—ones that likely did not affect the substantive outcome—do not satisfy the fourth prong of plain-error review.”