United States v. Addonizio et al.
442 U.S. 178 (1979)
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Rule of Law:
A subsequent change in the policies of the United States Parole Commission, which frustrates a sentencing judge's subjective expectations regarding a prisoner's release date, does not constitute a legal error that can be remedied through a collateral attack on the original sentence under 28 U.S.C. § 2255.
Facts:
- In 1970, Hugh J. Addonizio was convicted of extortion and sentenced to 10 years in federal prison.
- The sentencing judge imposed this sentence with the expectation that Addonizio, as a first-time offender, would likely be granted parole after serving about one-third of his term, assuming good institutional behavior.
- The judge did not anticipate that the Parole Commission would later use the severity of the offense itself as a primary reason to deny parole.
- In 1973, the Parole Commission implemented new guidelines that made the gravity of the offense a significant factor in parole determinations.
- When Addonizio became eligible for parole in 1975, the Parole Commission denied his release on two occasions, expressly citing the serious character of his crimes as the basis for the denial.
Procedural Posture:
- Addonizio filed a motion under 28 U.S.C. § 2255 in the United States District Court for the District of New Jersey, the court of first instance that imposed the original sentence.
- The District Court granted the motion, finding that its sentencing expectation had been frustrated, and reduced Addonizio's sentence to time served.
- The United States appealed the District Court's decision to the U.S. Court of Appeals for the Third Circuit.
- The Court of Appeals, as the intermediate appellate court, affirmed the District Court's judgment.
- The United States (petitioner) sought and was granted a writ of certiorari by the U.S. Supreme Court to review the decision.
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Issue:
Does a postsentencing change in the United States Parole Commission's policies, which frustrates the sentencing judge's subjective expectation of when a prisoner would be released, provide a valid basis for a collateral attack on the original sentence under 28 U.S.C. § 2255?
Opinions:
Majority - Justice Stevens
No. A postsentencing change in Parole Commission policies that frustrates a sentencing judge's expectations does not provide a valid basis for a collateral attack on the original sentence under § 2255. The Court reasoned that § 2255 is reserved for correcting fundamental errors that render a judgment irregular or invalid, such as a lack of jurisdiction, a constitutional violation, or an error that results in a 'complete miscarriage of justice.' The frustration of a judge's subjective intent does not meet this high standard, as the sentence itself was lawful when imposed and remains so. Congress has explicitly delegated the authority to make parole release decisions to the Parole Commission, an executive agency, not to the judiciary. Allowing judges to modify sentences years later based on their unfulfilled expectations would undermine this statutory separation of powers and the finality of judgments.
Analysis:
This decision reinforces the finality of criminal sentences and clarifies the distinct roles of the judicial and executive branches in the federal criminal justice system. The Court firmly established that the act of sentencing is a judicial function, while the execution of that sentence, including parole decisions, is an executive function. By limiting the scope of § 2255 collateral attacks, the ruling prevents federal courts from using frustrated expectations about parole as a backdoor to resentencing, thereby preserving the authority Congress granted to the Parole Commission. This holding significantly curtails a prisoner's ability to challenge their sentence based on subsequent changes in parole administration.
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