Stinson v. United States

Background

A defendant, Terry Lynn Stinson, pleaded guilty after robbing a Florida bank. At sentencing, a probation report recommended treating him as a “career offender” under the federal Sentencing Guidelines because one of his prior convictions was unlawful possession of a firearm by a felon (18 U.S.C. § 922(g)). The trial court relied on that firearm conviction as a qualifying “crime of violence” and sentenced him as a career offender. The Court of Appeals agreed but later refused to treat a subsequent change in the Guidelines’ commentary as binding.

Reasoning

The Court reviewed whether the Sentencing Commission’s commentary that interprets a guideline must be followed by federal courts. It held that interpretive or explanatory commentary is authoritative and controls unless it conflicts with the Constitution or a federal statute, or is plainly erroneous or inconsistent with the guideline text. Applying that rule, the Court found Amendment 433 — which added commentary saying felon‑in‑possession is not a “crime of violence” — did not violate the Constitution or federal law and was not plainly erroneous. Therefore the amendment’s commentary is binding where it applies.

Real world impact

The decision means federal judges must follow the Commission’s interpretive commentary in most cases when applying the Guidelines. The Court did not resolve whether the amendment applies retroactively to sentences already imposed; it left questions about resentencing and the proper procedure to the Court of Appeals on remand. This ruling resolves a split among appeals courts about how much weight to give guideline commentary.