Brief Fact Summary. Congress adopted the Sentencing Reform Act of 1984 (Act) in an effort to address the widespread disparity in the scope and extent of punishment in criminal cases in the United States. The Act created the United States Sentencing Commission devise guidelines for sentencing, and John M. Mistretta (Petitioner) challenged this as an unconstitutional delegation.
Synopsis of Rule of Law. The “intelligible principle test” applies to congressional delegations. As long as the act by Congress includes an intelligible principle to which the delegee is directed to conform, the legislative action is not a forbidden delegation of legislative power. The Supreme Court of the United States has ruled it “constitutionally sufficient if Congress clearly delineates the general policy, the public agency which it to apply it, and the boundaries of this delegated authority.”
Facts. Petitioner was indicted in the United States District Court for the Western District of Missouri on three counts centering in a cocaine sale, and moved to have the promulgated guidelines ruled unconstitutional on the grounds that Congress delegated excessive authority to the Sentencing Commission to structure the guidelines.
Issue. By delegating the power to promulgate sentencing guidelines for every federal criminal offense to the Sentencing Commission, did Congress grant excessive legislative discretion in violation of the nondelegation doctrine?