United States v. Benz

Background

A man named Benz was convicted under the National Prohibition Act, pleaded guilty, and was sentenced to ten months in prison beginning December 27, 1929. While he was serving that sentence the district court, over the Government’s objection, reduced his term from ten to six months. The Government appealed, and the lower court asked the high Court to answer whether a federal trial court may, during the same court term when it imposed a sentence, shorten that sentence after the defendant has already begun serving it.

Reasoning

The Court reviewed long-standing practice that courts control their own judgments during the term when they were entered and may amend them then. It explained that reducing a sentence is allowed so long as the punishment is not increased afterward, because increasing or re-imposing punishment would amount to double punishment. The Court distinguished earlier statements suggesting a broader rule and rejected the idea that a judicial reduction is the same as executive clemency. Cutting short a sentence by judicial amendment changes the judgment itself and is a judicial act, while pardons or commutations are executive actions that abridge enforcement but do not alter the judgment qua judgment.

Real world impact

The decision means trial judges have the power to shorten criminal terms during the same court term even after part of the sentence has been served. It confirms that such reductions do not usurp the President’s pardon power, and it reiterates that courts may not increase punishment already partly served because of the protection against double punishment.