United States v. Addonizio

Background

Three federal prisoners, including Hugh J. Addonizio, challenged the effect of a later Parole Commission policy change on their actual time in prison. Addonizio had been sentenced to ten years and a fine; the sentencing judge expected that, with good behavior, parole eligibility after one-third of the term would lead to release much earlier. In 1973 the Parole Commission adopted guidelines that made the seriousness of the offense a major factor, and the Commission denied parole, citing the gravity of Addonizio’s crimes. The District Court granted relief under 28 U.S.C. §2255 and the Court of Appeals affirmed, but the Government appealed to the Supreme Court.

Reasoning

The Court considered only whether these facts allow a collateral attack under §2255. It explained that §2255 preserves a narrow role for reopening final sentences — mainly where a court lacked jurisdiction, the sentence exceeded the law, or there was a fundamental constitutional or factual defect. A later change in how parole is handled, even if it frustrates a judge’s subjective expectation about release, does not make the original sentence unlawful. The Court emphasized that Congress entrusted release timing largely to the Parole Commission and limited judges’ power to alter sentences after they are final.

Real world impact

The decision means prisoners cannot use §2255 to undo or shorten sentences simply because parole procedures changed after sentencing. Parole decisions remain for the Parole Commission under statutory rules, and trial judges’ informal expectations about release are not enforceable grounds for reopening sentences. The Court declined to rule on whether the Commission’s new guidelines themselves are lawful.