U.S. Supreme Court 06-16-11
by: Grapkoch • June 15, 2011 • no comments
Read the full article for details about the following new cases:
- The Prohibition on Imprisonment as a Means of Promoting Rehabilitation
According to SCOTUSblog, Tapia v. United States held that 18 U.S.C. § 3582(a) does not permit a sentencing court to impose or lengthen a prison term to foster a defendant's rehabilitation. That was the issue on which cert. was granted, but the Court's opinion actually states the proposition in somewhat different terms: "We consider here whether the Sentencing Reform Act precludes federal courts from imposing or lengthening a prison term in order to promote a criminal defendant's rehabilitation. We hold that it does." (Emphasis added).
Looking to the opinion, Tapia had argued that § 3582(a) instructs sentencing courts to "recogniz[e] that imprisonment is not an appropriate means of promoting correction and rehabilitation." That argument, notes the Court, also stems in part from the SRA's dictate to the Sentencing Commission that it "'insure that the guidelines reflect the inappropriateness of imposing a sentence to a term of imprisonment for the purpose of rehabilitating the defendant or providing the defendant with needed educational or vocational training, medical care, or other correctional treatment.' 28 U.S.C. § 994(k)." . After running through the history, text and structure of the SRA, the Court is tasked with determining whether the exclusion of rehabilitation from § 3582(a)'s "recognition" format amounts to a "prohibition" as Tapia suggests. And, despite amicus's contentions to the contrary, the Court concludes that it does:
"we do not see how these alternative meanings of "recognize" help amicus's cause. A judge who "perceives clearly" that imprisonment is not an appropriate means of promoting rehabilitation would hardly incarcerate someone for that purpose. Ditto for a judge who "realizes" or "recalls" that imprisonment is not a way to rehabilitate an offender. To be sure, the drafters of the "recognizing" clause could have used still more commanding language: Congress could have inserted a "thou shalt not" or equivalent phrase to convey that a sentencing judge may never, ever, under any circumstances consider rehabilitation in imposing a prison term. But when we interpret a statute, we cannot allow the perfect to be the enemy of the merely excellent. Congress expressed itself clearly in §3582(a), even if armchair legislators might come up with something even better. And what Congress said was that when sentencing an offender to prison, the court shall consider all the purposes of punishment except rehabilitation-because imprisonment is not an appropriate means of pursuing that goal."
Furthermore, the Court also rejects amicus's position that even if the prohibition applies, it applies only to the imposition rather than the lengthening of a sentence. As a textual matter, the Court notes, "the word 'imprisonment' does not change the function of the 'recognizing' clause-to constrain a sentencing court's decision both to impose and to lengthen a prison term." And "[t]he context of §3582(a) puts an exclamation point on this textual conclusion .Each actor at each stage in the sentencing process receives the same message: Do not think about prison as a way to rehabilitate an offender."
And the Court does not stop there, it continues to run through the statutory silence and legislative history supporting its conclusion. In short, "this is a case in which text, context, and history point to the same bottom line: Section 3582(a) precludes sentencing courts from imposing or lengthening a prison term to promote an offender's rehabilitation."
A concurring opinion by Justice Sotomayor (joined by Justice Alito!) follows the majority. More information on Tapia v. United States can be found at the SCOTUSblog case page, available here.
