''Tapia v. United States'', 564 U.S. 319 (2011), was a
United States Supreme Court case in which the Court held that a federal court cannot give a criminal defendant a longer
sentence to promote
rehabilitation
Rehabilitation or Rehab may refer to:
Health
* Rehabilitation (neuropsychology), therapy to regain or improve neurocognitive function that has been lost or diminished
* Rehabilitation (wildlife), treatment of injured wildlife so they can be retur ...
.
Background
Alejandra Tapia was sentenced to 51 months in federal prison for bringing an illegal immigrant into the United States for financial gain.
United States v. Tapia
', No. 09-50248, (9th Cir. April 16, 2010). Tapia challenged the basis for the District Court's sentencing decision. Specifically, Tapia challenged basing the length of sentence on speculation about when Tapia would be able to enter and complete the
Bureau of Prisons
The Federal Bureau of Prisons (BOP) is a United States federal law enforcement agency under the Department of Justice that is responsible for the care, custody, and control of incarcerated individuals who have committed federal crimes; that i ...
' drug abuse treatment program.
In a brief order, the
Ninth Circuit Court of Appeals, relying on its previous decisions, affirmed the decision.
Tapia petitioned the Supreme Court for
certiorari
In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...
, citing the
circuit split on the issue. Specifically, the Eighth and Ninth Circuits permit the use of rehabilitation as a factor in sentencing, while four other circuit courts prohibit it. The Court agreed to hear the case on that issue.
Questions presented in No. 10-5400, Tapia v. United States
Supreme Court of the United States.
Opinion of the Court
The issue before the Court was whether the Sentencing Reform Act precludes a federal court from imposing or lengthening a prison term for the purposes of prompting rehabilitation. The Court held in a unanimous opinion that it does. First considered by the Court was the language of the Sentencing Reform Act, specifically that a court must "recogniz that imprisonment is not an appropriate means of promoting correction and rehabilitation." Further, the act instructs the courts to acknowledge this fact when "determining whether to impose a term of imprisonment, and... hendetermining the length of the term."
Concurrence
Justice Sotomayor wrote a concurring opinion, joined by Justice Alito, in which she expressed "skepticism that the District Judge ad actuallyviolated this proscription in this case".
References
External links
* {{caselaw source
, case = ''Tapia v. United States'', {{Ussc, 564, 319, 2011, el=no
, justia =https://supreme.justia.com/cases/federal/us/564/319/
, oyez =https://www.oyez.org/cases/2010/10-5400
, other_source1 = Supreme Court (slip opinion) (archived)
, other_url1 =https://web.archive.org/web/0/https://www.supremecourt.gov/opinions/10pdf/10-5400.pdf
Tapia v. United States
coverage on SCOTUSblog
United States Supreme Court cases
United States Federal Sentencing Guidelines case law
2011 in United States case law
United States Supreme Court cases of the Roberts Court