Stinson v. United States
1993 U.S. LEXIS 3124, 123 L. Ed. 2d 598, 508 U.S. 36 (1993)
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Rule of Law:
Commentary in the U.S. Sentencing Guidelines Manual that interprets or explains a guideline is authoritative and binding on federal courts unless it violates the Constitution or a federal statute, or is a plainly erroneous reading of, or is inconsistent with, that guideline.
Facts:
- Terry Lynn Stinson robbed a bank in Florida and pleaded guilty to a five-count indictment, which included a charge for possession of a firearm by a convicted felon.
- At the time of the offense, Stinson was over eighteen years old and had at least two prior felony convictions for crimes of violence.
- The U.S. Sentencing Guidelines designated a defendant as a "career offender" subject to enhanced sentencing if, among other things, their current offense was a "crime of violence."
- The definition of "crime of violence" at the time included any offense that "involves conduct that presents a serious potential risk of physical injury to another."
- After Stinson was sentenced, the U.S. Sentencing Commission issued Amendment 433, which added commentary to the relevant guideline stating explicitly that the "term 'crime of violence' does not include the offense of unlawful possession of a firearm by a felon."
Procedural Posture:
- Terry Lynn Stinson pleaded guilty in the U.S. District Court for the Middle District of Florida.
- The District Court determined that possession of a firearm by a felon was a 'crime of violence' and sentenced Stinson as a career offender under the Sentencing Guidelines.
- Stinson, as appellant, appealed to the U.S. Court of Appeals for the Eleventh Circuit.
- The Court of Appeals affirmed the trial court's sentence.
- While Stinson's petition for rehearing was pending, the Sentencing Commission issued Amendment 433, adding commentary clarifying that the felon-in-possession offense is not a 'crime of violence.'
- The Court of Appeals denied rehearing, holding that the Commission's commentary was not binding on the courts.
- The U.S. Supreme Court granted certiorari to resolve a conflict among the Courts of Appeals on this issue.
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Issue:
Is commentary in the U.S. Sentencing Guidelines Manual that interprets or explains a guideline binding on federal courts?
Opinions:
Majority - Justice Kennedy
Yes, commentary that interprets or explains a guideline is binding on federal courts. Such commentary is authoritative unless it is inconsistent with the Constitution, a federal statute, or the guideline itself, or is a plainly erroneous reading of the guideline. The Court reasoned that commentary should be treated as an agency's interpretation of its own legislative rule. Under the principle established in Bowles v. Seminole Rock & Sand Co., an agency's interpretation of its own regulation is given controlling weight unless it is plainly erroneous or inconsistent with the regulation. The Sentencing Commission drafts both the guidelines and the commentary, making the commentary the most accurate indication of how the Commission intends the guidelines to be applied. The Court rejected analogies to legislative history or Chevron deference, finding the agency-interpretation model most appropriate. Therefore, the commentary in Amendment 433, which clarifies that being a felon-in-possession of a firearm is not a crime of violence, is a binding interpretation that federal courts must follow.
Analysis:
This decision significantly strengthens the authority of the U.S. Sentencing Commission by establishing that its commentary is binding law, not merely persuasive guidance. It resolved a circuit split and created a uniform national standard for applying the Guidelines Manual, ensuring more consistent sentencing outcomes. The ruling empowers the Commission to clarify or even effectively alter the application of guidelines through commentary amendments, a process that does not require congressional review. This elevates the importance of the entire Guidelines Manual, requiring judges and practitioners to give the same legal weight to interpretive commentary as they do to the guidelines themselves.
