United States v. Batchelder

Supreme Court of United States
442 U.S. 114 (1979)

ELI5:

Rule of Law:

When a defendant's conduct violates two separate criminal statutes with different penalties, the government has the discretion to prosecute under either statute, and the defendant may be sentenced under the penalty provision of the statute for which they were convicted, even if it is the harsher of the two.

Facts:

Batchelder was a previously convicted felon.
Batchelder received a firearm that had been transported in interstate commerce.
This single act violated two distinct provisions of the Omnibus Crime Control and Safe Streets Act of 1968.
One provision, 18 U.S.C. § 922(h), carried a maximum penalty of five years' imprisonment as prescribed by § 924(a).
The other provision, 18 U.S.C. App. § 1202(a), prohibited virtually identical conduct for a convicted felon but carried a maximum penalty of only two years' imprisonment.

Procedural Posture:

The United States indicted Batchelder in U.S. District Court for violating 18 U.S.C. § 922(h), the statute with the five-year maximum penalty.
A jury found Batchelder guilty.
The District Court (trial court) sentenced Batchelder to five years' imprisonment, the maximum authorized by § 924(a).
Batchelder (appellant) appealed to the U.S. Court of Appeals for the Seventh Circuit, challenging the sentence.
The Court of Appeals (intermediate appellate court) affirmed the conviction but vacated the sentence, holding that Batchelder could only be sentenced under the more lenient two-year maximum of the overlapping statute, § 1202(a).
The United States (petitioner) successfully petitioned the U.S. Supreme Court for a writ of certiorari.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does the existence of two overlapping federal statutes prohibiting the same conduct but authorizing different maximum penalties require a defendant convicted under the statute with the harsher penalty to be sentenced according to the more lenient statute?

Opinions:

Majority - Justice Marshall

No. When a defendant's conduct violates two statutes, the government may prosecute under either, and the penalty of the statute of conviction applies. The statutes, §§ 922(h) and 1202(a), are independent provisions with their own self-contained penalty schemes. The plain language and legislative history of the Omnibus Act show that Congress intended them to operate separately, with Title VII's § 1202(a) meant to complement, not supplant, Title IV's § 922(h). The principles of lenity, implied repeal, and constitutional avoidance are inapplicable because the statutory language is unambiguous. The prosecutor's discretion to choose between the two statutes does not violate due process, equal protection, or the nondelegation doctrine, as the statutes provide clear notice of prohibited conduct and potential penalties, and this discretion is analogous to other permissible charging decisions.

Analysis:

This case solidifies the principle of prosecutorial discretion in the charging process, affirming the government's power to select among overlapping statutes, even when that choice dictates a substantially harsher penalty. The Court rejected the notion that the rule of lenity could be used to merge sentencing provisions from separate, unambiguous statutes. This decision empowers prosecutors by allowing them to leverage the harsher of two applicable laws, thereby strengthening their position in plea negotiations and at sentencing. It establishes that as long as Congress clearly enacts separate criminal prohibitions, the resulting sentencing disparity for the same conduct is constitutionally permissible.

Gunnerbot

AI-powered case assistant

Loaded: United States v. Batchelder (1979)

Try: "What was the holding?" or "Explain the dissent"