Miller v. Florida

Supreme Court of United States
482 U.S. 423 (1987)

ELI5:

Rule of Law:

A law violates the Ex Post Facto Clause of the U.S. Constitution if it is applied retrospectively to events occurring before its enactment and it disadvantages the offender by making the punishment for a crime more onerous.

Facts:

On April 25, 1984, Ronald Miller committed several offenses, including sexual battery.
At the time of Miller's offenses, Florida's sentencing guidelines prescribed a presumptive sentence range of 3.5 to 4.5 years for his crimes.
Under the guidelines then in effect, a judge could impose a sentence outside this range only by providing 'clear and convincing reasons' in writing, a decision which would be subject to appellate review.
After Miller committed his crimes but before he was sentenced, Florida's legislature revised the sentencing guidelines, effective July 1, 1984.
The revisions included a 20% increase in the points assigned to sexual offenses, which changed the presumptive sentence for Miller's crimes.
Under the revised guidelines, the new presumptive sentence range for Miller's crimes became 5.5 to 7 years.

Procedural Posture:

Ronald Miller was convicted on several counts, including sexual battery, in a Florida trial court.
At sentencing, the trial court rejected Miller's ex post facto argument and applied the revised sentencing guidelines that were in effect at the time of sentencing, imposing a 7-year prison term.
Miller, as appellant, appealed to the Florida District Court of Appeal, which vacated the sentence, finding the application of the new guidelines was an ex post facto violation, and remanded for re-sentencing.
The State of Florida, as appellant, appealed to the Supreme Court of Florida.
The Supreme Court of Florida reversed the appellate court's decision, holding that the change in guidelines was merely procedural and did not violate the Ex Post Facto Clause.
The U.S. Supreme Court granted certiorari to review the decision of the Supreme Court of Florida.

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Issue:

Does the retrospective application of revised state sentencing guidelines, which increase the presumptive sentence for a crime, to a defendant who committed the crime before the guidelines were enacted, violate the Ex Post Facto Clause?

Opinions:

Majority - Justice O’Connor

Yes, the retrospective application of the revised sentencing guidelines violates the Ex Post Facto Clause. A law is unconstitutional under the clause if it is both retrospective and disadvantages the offender. Here, the law is clearly retrospective as it was applied to Miller's conduct which occurred before the law's effective date. The law also disadvantaged Miller by increasing his presumptive sentence range from 3.5-4.5 years to 5.5-7 years. This change is not merely procedural; it is a substantive alteration that makes the punishment for his crime more onerous. Under the old law, a 7-year sentence would have been an upward departure requiring written justification and subject to appeal, whereas under the new law, it is a standard sentence requiring no special justification and is unreviewable. This loss of the opportunity to challenge the longer sentence is a substantial disadvantage, regardless of what sentence he might have received under the old scheme.

Analysis:

This decision solidifies the principle that sentencing guidelines, not just statutory maximums, are subject to Ex Post Facto analysis. It clarifies that a change in law is unconstitutionally 'onerous' if it reduces the defendant's opportunity to receive a lesser sentence or restricts their ability to challenge a harsher one. The Court's rejection of the 'procedural' label for a change that has a clear substantive impact on the 'quantum of punishment' set a precedent for looking at the practical effects of legal changes on a defendant's rights. This case significantly impacts how legislative bodies can amend sentencing structures, requiring that any changes that disadvantage defendants can only be applied prospectively.

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