In a case that should be of interest to criminal law practitioners, the U.S. Supreme Court has issued a decision reinforcing the wide discretion that federal judges have in sentencing under the now-advisory Sentencing Guidelines. The court’s short (eight-page), unanimous opinion by Chief Justice John Roberts holds that, in crafting a defendant’s sentence on one count of conviction, a sentencing court may consider a consecutive mandatory minimum that must be imposed on another count.
In Dean v. United States, decided on April 3, 2017, the 23-year-old defendant, who had participated in several robberies of drug dealers, was convicted of one count of conspiracy to commit robbery, two counts of robbery, and one count of possessing a firearm as a convicted felon. He was also convicted of two counts of possessing a firearm in furtherance of a crime of violence in violation of 18 U.S.C. §924(c)—counts requiring imposition of a 30-year mandatory minimum sentence consecutive to “any other term of imprisonment imposed on the person.”
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