Rita v. United States
Issues
1) Is the minimum sentence, within the range of sentences set out for a particular crime by the Federal Sentencing Guidelines, reasonable when relevant factors suggest that a reduced sentence may be appropriate?
2) If an offender’s sentence is within the range of sentences set out for a particular crime by the Federal Sentencing Guidelines, may a court of appeals approve this sentence without considering other relevant factors?
3) If the appeals court may approve a sentence without considering other relevant factors, may the sentencing court give a sentence without explaining the roll that these relevant factors played in the sentencing decision?
Victor Rita, a 25-year military veteran, was convicted of making false statements to a grand jury. At sentencing, Rita argued that his distinguished military service, his likelihood of being targeted in prison and his physical ailments justified a more lenient sentence than those set out in the Federal Sentencing Guidelines. A District Court judge determined that he should receive the minimum sentence set fourth in the Federal Sentencing Guidelines for his conviction. Upon appeal, the Fourth Circuit Court of Appeals expressed its view that a within-guideliness sentence was presumptively reasonable and upheld Rita’s sentence. In reviewing this case, the Supreme Court will clarify the role that the Federal Sentencing Guidelines are to play in sentencing decisions.
Questions as Framed for the Court by the Parties
1) Was the District Court’s choice of within-guidelines sentence reasonable?
2) In making that determination, is it consistent with United States v. Booker, 543 U.S. 220 (2005), to accord a presumption of reasonableness to within-guidelines sentences?
3) If so, can that presumption justify a sentence imposed without an explicit analysis by the district court of the 18 U.S.C. §3553(a) factors and any other factors that might justify a lesser sentence?
In 2003 the Bureau of Alcohol, Tobacco and Firearms commenced an investigation of InterOrdnance, a gun dealing business. Brief for United States at 2. The Bureau determined that InterOrdnance brand “parts kits,” which could be assembled into PPSH 41 World War II rifle replicas, should qualify as “machine guns.” Brief for Petitioner at 2.