Wade v. United States

United States Supreme Court
504 U.S. 181 (1992)

ELI5:

Rule of Law:

A federal district court has the authority to review a prosecutor’s refusal to file a substantial-assistance motion for a downward departure from a mandatory minimum sentence, but only if the defendant makes a substantial threshold showing that the refusal was based on an unconstitutional motive, such as race or religion.

Facts:

On October 30, 1989, police searched the home of Harold Ray Wade, Jr., and discovered cocaine, two handguns, and over $22,000 in cash.
Following his arrest, Wade provided law enforcement officials with information.
The information Wade provided led to the arrest of another individual involved in drug dealing.
Despite Wade's assistance, the Government declined to file a motion with the court stating that he had provided "substantial assistance."
Such a motion would have allowed the court to sentence him below the mandatory minimum sentence required by statute.

Procedural Posture:

A federal grand jury indicted Harold Ray Wade, Jr., on four counts related to drug and firearm offenses.
Wade pleaded guilty to all counts in the U.S. District Court (trial court).
At sentencing, the District Court ruled it lacked authority to depart below the mandatory minimum sentence without a substantial-assistance motion from the Government, and sentenced Wade to 180 months in prison.
Wade (appellant) appealed to the United States Court of Appeals for the Fourth Circuit.
The Court of Appeals affirmed the District Court's sentence, holding that judicial review of the prosecutor's discretionary refusal to file the motion was not permissible.
The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals.

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Issue:

Do federal district courts have the authority to review the government's refusal to file a substantial-assistance motion for a downward sentencing departure, where the refusal is allegedly based on an unconstitutional motive?

Opinions:

Majority - Justice Souter

Yes. Federal district courts have the authority to review a prosecutor's refusal to file a substantial-assistance motion if there is a claim that the refusal was based on an unconstitutional motive. Prosecutorial discretion, while broad, is subject to constitutional limitations. A prosecutor's decision not to file a substantial-assistance motion is reviewable on the same terms as other prosecutorial decisions, such as selective prosecution. Therefore, a defendant is entitled to a remedy if the government's refusal was based on a suspect classification like race or religion, or was not rationally related to any legitimate government end. However, to obtain a remedy or even an evidentiary hearing, a defendant must make a 'substantial threshold showing' of an unconstitutional motive; a mere claim of having provided assistance is insufficient. In this case, Wade failed to allege or provide any evidence that the government acted with an unconstitutional motive.

Analysis:

This case establishes a critical, albeit narrow, judicial check on the executive branch's prosecutorial discretion in the context of federal sentencing. While affirming the government's power to control access to sentence reductions for substantial assistance, the Court carves out an exception for decisions tainted by unconstitutional motives. The ruling sets a high bar for defendants, requiring a 'substantial threshold showing' of improper motive, which is difficult to meet in practice. This decision balances the need to protect prosecutorial authority against the imperative to uphold fundamental constitutional rights, ensuring that a defendant has a potential remedy against invidious discrimination in the sentencing process.

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