United States v. Deegan

Brief Fact Summary. Deegan (D), a Native American, abandoned the baby boy she had given birth to for two weeks in her home. The child however died before she returned to the house.

Synopsis of Rule of Law. Appeals courts should accord a sentence imposed by a federal district court with a presumption of reasonableness in a situation whereby a federal district court imposes the sentence within the applicable range of the advisory federal sentencing guidelines.

Facts. Deegan (D), a Native American, abandoned her baby boy in her home on the Fort Berth Indian Reservation for a period of two weeks. The baby died before she returned. Her attempt to throw the corpse away in a suitcase was discovered. Deegan (D) was charged to court in a federal court with second-degree murder because the incident had happened on an Indian Reservation. The lower court found her guilty and summarily sentenced her to ten years in prison. This sentence was however at the low end of the suggested range as stipulated in the advisory federal sentencing guidelines.
Deegan’s (D) long history of physical and sexual abuse at the hands of her family members which included her dad and the father of four of her children as well as a report from a physician who described her depression at the time of the incident were all considered by the court. But due to her intentional action in killing her son, the court did not depart from the sentencing guidelines. On this premise, Deegan (D) appealed for a deviation from the sentencing guidelines based on her history of sexual and physical abuse.

Issue. Should appeal courts accord a sentence imposed by a federal district court with a presumption of reasonableness in a situation whereby a federal district court imposed the sentence within the applicable range of the advisory federal sentencing guidelines?

Held. (Collton, J.) Yes. Appeals courts should accord a sentence imposed by a federal district court with a presumption of reasonableness in a situation whereby a federal district court imposes the sentence within the applicable range of the advisory federal sentencing guidelines. Stipulated in the guidelines is the provision that when a judge’s sentence is within the suggested sentences for the typical type of case, such sentence is likely reasonable. Mitigating and aggravating factors can be identified and the court also took notice of the physical and sexual abuse suffered by Deegan (D). Although the dissent points to state cases with three-year sentences, the federal courts are prohibited under the guidelines to consider the length of sentences in analogous state cases. Hence, the ruling was sustained.

Dissent. (Bright, J.) when Deegan’s (D) life history which is characterized with sexual and physical abuse is put into consideration, then the sentence is erroneous. Instead of a ten-year sentence, analogous state sentences are only three years. Hence, the lower court should have deviated from the guildelines and imposed a lesser sentence on Deegan (D).

Discussion. still now, most courts use the suggested range when sentencing even when the federal sentencing guidelines are no longer mandatory. The issue here is that if this incidence had not occurred on a federal Indian Reservation, it would have been prosecuted in the state court.