Melendez v. United States

Background

A defendant who admitted joining a scheme to buy large quantities of cocaine pleaded guilty and agreed to cooperate with the Government. The plea said the Government would move under the Sentencing Guidelines (§5K1.1) to ask for a lower guideline sentence. The Government moved under §5K1.1 to reduce the guideline range but did not file a separate motion under the statute (18 U.S.C. §3553(e)) asking the court to impose a sentence below the 10-year statutory minimum. The district court reduced the guideline sentence but said it could not go below the 10-year statutory minimum and imposed the minimum instead. The Government’s and petitioner’s dispute reached the Supreme Court.

Reasoning

The core question was whether a Government motion under the Guidelines alone lets a judge impose a sentence below a statutory minimum. The Court said no: the statute plainly requires an explicit Government motion authorizing a below-minimum sentence. The Sentencing Commission’s policy statement (§5K1.1) and its commentary do not replace that statutory motion requirement. The Court concluded that, without a separate motion under the statute, a judge lacks authority to impose a sentence below the statutory minimum.

Real world impact

The ruling means prosecutors must file a specific statutory motion if they want a below-minimum sentence for a cooperating defendant; judges cannot rely on a §5K1.1 guideline motion alone to go below mandatory minimums. The decision resolved conflicting appeals-court views and clarifies who must authorize below-minimum sentences.

Dissents or concurrances

Justices agreed on the result but differed about the Guidelines’ role: Justice Souter read the Application Notes as applying to statutory minimums; Justice Stevens agreed with the judgment; Justice Breyer (joined by O’Connor) thought the Commission intended a unitary motion system and dissented in part.