Carlesi v. New York

Background

A man was charged in New York with forgery as a second offense. The indictment relied on an earlier federal conviction for selling counterfeit coin and the sentence he served. After he completed that sentence, the President granted him a pardon. He admitted the prior conviction but asked the state court not to consider it because of the presidential pardon. New York’s law lets a court increase punishment for a new crime when the defendant has a prior felony conviction from another jurisdiction. State courts rejected his argument and the record came to this Court on the federal issue.

Reasoning

The key question was whether a pardon from the President for a federal crime prevents a State from using that pardoned conviction when sentencing a later state crime. Relying on earlier Supreme Court decisions, the Court treated the state law as punishment only for the new crime, not as additional punishment for the old one. The Court explained that counting a past conviction to increase a sentence for a new state offense is an exercise of the State’s sentencing power, not a way to undermine the federal pardon. Because the state action did not amount to punishing the pardoned federal offense, it did not conflict with the Constitution or the President’s pardon power.

Real world impact

People who receive a presidential pardon for a federal crime can still have that past conviction counted by a State when they commit a later state offense. States remain free to shape sentences for new crimes based on an offender’s prior record. The Court also noted this ruling does not limit how the United States may consider past offenses in federal punishments or laws.