United States v. Cortes

697 F. Supp. 1305, 1988 U.S. Dist. LEXIS 11818, 1988 WL 111547
CourtDistrict Court, S.D. New York
DecidedOctober 7, 1988
Docket88 Cr. 159 (SWK)
StatusPublished
Cited by2 cases

This text of 697 F. Supp. 1305 (United States v. Cortes) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Cortes, 697 F. Supp. 1305, 1988 U.S. Dist. LEXIS 11818, 1988 WL 111547 (S.D.N.Y. 1988).

Opinion

MEMORANDUM OPINION AND ORDER

KRAM, District Judge.

Defendant Dezerrie Cortes challenges the Sentencing Guidelines (“the Guidelines”) promulgated by the United States Sentencing Commission (“the Commission”) as violative of the United States Constitution (“the Constitution”) and the Sentencing Reform Act (“the Act”). Cortes has been charged with the distribution of, and possession with intent to distribute, cocaine in the form commonly known as “crack” in violation of 21 U.S.C. §§ 812, 841(a)(1), 841(b)(1)(B) and 18 U.S.C. § 2. Defendant is currently engaged in plea negotiations with the government regarding these charges.

BACKGROUND

The Sentencing Reform Act created the Sentencing Commission, as “an independent commission in the judicial branch....” 28 U.S.C. § 991(a). The Sentencing Commission consists of seven voting members, three of whom must be federal judges selected by the President. Id. Congress delegated to the Commission the authority to create guidelines to provide a structure for evaluating the fairness and appropriateness of punishment for individual offenders, and to establish greater uniformity in sentencing. Pursuant to this mandate, the Commission created the Sentencing Guidelines at issue, which became effective on November 1, 1987, as provided for by the Comprehensive Crime Control Act of 1984, Pub.L. 98-473, 98 Stat. 1837, 2017.

The defendant in the present case makes several constitutional and non-constitutional attacks on the Guidelines, the most compelling of which is that the placement of Article III judges on the Commission violates Article III and the separation of powers doctrine. Cortes further claims that the President’s power to remove the judges from the Commission impairs the neutrality of the Commission, thereby violating the separation of powers and depriving her of due process of law. 1 Cortes also argues that Congress’s delegation of authority to the Commission is unlawful because it fails to create adequate and sufficiently intelligible guidance to the Commission. The defendant also attacks alleged inconsistencies between the Act’s provisions and the Guidelines.

*1307 DISCUSSION

Ripeness

The government raises a ripeness argument, contending that the defendant’s motion to challenge the Guidelines is unfit for judicial decision until she either pleads guilty or is convicted. The defendant argues that she cannot consider a plea while the constitutionality of the Sentencing Guidelines remains at issue because, among other things, the possible range of sentence under the old law is dramatically different from that under the Guidelines. Several district courts have held that a constitutional attack on the Guidelines is a ripe controversy even though the defendant has neither plead guilty nor been tried and convicted. See, e.g., United States v. Olivencia, 689 F.Supp. 1319 (S.D.N.Y. 1988); United States v. Macias-Pedroza, 694 F.Supp. 1406 (D.Ariz.1988); United States v. Ruiz-Villanueva, 680 F.Supp. 1411 (S.D.Cal.1988); United States v. Arnold, 678 F.Supp. 1463 (S.D.Cal.1988).

As a threshold inquiry, this Court must decide whether the defendant’s constitutional challenge to the Sentencing Guidelines establishes a concrete case or controversy. Thomas v. Union Carbide Agricultural Products, 473 U.S. 568, 579, 105 S.Ct. 3325, 3332, 87 L.Ed.2d 409 (1985); Regional Rail Reorganization Act Cases, 419 U.S. 102, 138-39, 95 S.Ct. 335, 355-56, 42 L.Ed.2d 320 (1974). The basic rationale of the ripeness doctrine is to prevent the courts, through premature adjudication, from entangling themselves in abstract disagreements. Thomas, 473 U.S. at 580, 105 S.Ct. at 3332.

Ripeness analysis involves a two-part consideration of “both the fitness of the issues for judicial decision and the hardship to the parties of withholding court consideration.” Abbott Labs v. Gardner, 387 U.S. 136, 149, 87 S.Ct. 1507, 1515, 18 L.Ed. 2d 681 (1967). On the issue of fitness for judicial decision, the government contends that since the sentencing of Cortes is a contingent event that may never occur, it is unfit for judicial consideration. As the government argues, the defendant may decide to enter a not guilty plea and thereafter be acquitted at trial. The Supreme Court, however, has held that a purely legal issue that requires no further factual development to clarify the dispute is more likely than not to be fit for review. Thomas, 473 U.S. at 581, 105 S.Ct. at 3333. Clearly, the constitutional attack on the Sentencing Guidelines presents a purely legal issue that can be resolved with no further factual development.

The second part of this analysis involves consideration of the hardships the parties would suffer if this Court refrained from considering defendant’s motion. The Guidelines, if applied, would significantly limit the range of Cortes’s probable sentence, creating a significant disparity between the possible range of sentences under the Guidelines as compared to pre-Guideline law. 2 The disparity between the prior sentencing scheme and the Guidelines highlights the uncertainty Cortes will face if forced to rely on a set of Guidelines “whose authority is undermined because its constitutionality is in question.” Thomas, 473 U.S. at 581, 105 S.Ct. at 3333.

The Constitution requires that all guilty pleas be voluntarily and intelligently made. See North Carolina v. Alford, 400 U.S. 25, 31, 91 S.Ct. 160, 164, 27 L.Ed.2d 162 (1970). Furthermore, the Federal Rules of Criminal Procedure require that this Court inform the defendant of, and determine that he understands, “the mandatory minimum penalty provided by law, if any, and the maximum possible penalty provided by law for the offense to which the plea is offered.” Fed.R.Crim.P. 11(c)(1). These requirements may not be met, at least as a practical matter, if Cortes makes her plea *1308 decision before this Court determines the applicability of the Guidelines.

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Related

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Cite This Page — Counsel Stack

Bluebook (online)
697 F. Supp. 1305, 1988 U.S. Dist. LEXIS 11818, 1988 WL 111547, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-cortes-nysd-1988.