United States v. Haymond (U.S. 2019)

United States v. Haymond, 588 U.S. _____ (U.S. 2019)

Nature of Case: Haymond was convicted of a federal sex offense related to the possession of illegal images and sentenced to a prison term, as well as a period of federal supervised release. A provision of federal law, 18 USC § 3583(k), provided that if and individual (like Haymond) was required to register as a sex offender and violated their supervised release by committing one of a series of offenses enumerated in the statute, then the judge must impose a mandatory minimum term of imprisonment of at least five years.

When Haymond was on his supervised release term, his probation officer discovered what appeared to be illegal images on his cell phone, and sought to have his supervised release revoked on that basis. The trial judge found, on a preponderance of the evidence standard that Haymond committed one of the offenses enumerated in § 3583(k) and thus imposed the mandatory minimum term of imprisonment on him. Haymond sought review from the Tenth Circuit Court of Appeals, which held that the challenged provisions of § 3583(k) are unenforceable and unconstitutional. Supreme Court granted review.

Holding: United States Supreme Court held that § 3583(k)’s imposition of mandatory terms of imprisonment on the basis of a preponderance finding that an offense was committed violates the Fifth and the Sixth Amendment’s right to a trial by jury and Due Process. Relying on the rationale established by Apprendi, the Court observed that the government is not free to impose mandatory minimum terms of imprisonment on the basis of the commission of a new criminal offense without the protections afforded by the constitution.