Stinson v. United States
Overview
Overview
Stinson v. United States (1993) is a unanimous Supreme Court decision, written by Justice Kennedy, holding that commentary in the U.S. Sentencing Guidelines Manual that interprets or explains a guideline is authoritative and binding on the federal courts unless it violates the Constitution or a federal statute, or is inconsistent with, or a plainly erroneous reading of, that guideline.
The Facts
Facts
Terry Lynn Stinson pleaded guilty to charges arising from a Florida bank robbery. The presentence report recommended sentencing him as a career offender under Sentencing Guidelines section 4B1.1, which required, among other things, that the offense of conviction be a 'crime of violence.' The district court treated his prior conviction for possession of a firearm by a convicted felon (18 U.S.C. section 922(g)) as a crime of violence and sentenced him as a career offender. After the Eleventh Circuit affirmed, the Sentencing Commission adopted Amendment 433, which added commentary to section 4B1.2 stating that 'crime of violence' does not include unlawful possession of a firearm by a felon. The Eleventh Circuit declined to follow the new commentary, holding that Guidelines commentary is only persuasive and not binding on the courts.
The Issue
Issue
Whether commentary in the United States Sentencing Guidelines Manual that interprets or explains a guideline is binding on the federal courts.
The Rules
Rule
Commentary in the Guidelines Manual that interprets or explains a guideline is authoritative unless it violates the Constitution or a federal statute, or is inconsistent with, or a plainly erroneous reading of, that guideline. Because the Sentencing Commission both writes the guidelines and the commentary interpreting them, the commentary is treated like an agency's interpretation of its own legislative rule, which controls unless plainly erroneous or inconsistent with the regulation (Bowles v. Seminole Rock & Sand Co., 325 U.S. 410 (1945)).
The Application
Analysis
The Court, in a unanimous opinion by Justice Kennedy, rejected the Eleventh Circuit's view that commentary is merely persuasive. It analogized interpretive commentary to an agency's reading of its own regulation and held it controlling under the Seminole Rock standard. Applying that standard to Amendment 433, the Court found the exclusion of the felon-in-possession offense from 'crime of violence' was not compelled by the guideline text but did not violate the Constitution or a statute and was not plainly erroneous or inconsistent with section 4B1.2. The commentary was therefore a binding interpretation, and felon-in-possession could not serve as the predicate crime of violence for the career-offender enhancement for defendants to whom Amendment 433 applies. The Court declined to reach the government's alternative nonretroactivity argument, leaving it for the Court of Appeals on remand.
The Conclusion
Conclusion
The Supreme Court vacated the Eleventh Circuit's judgment and remanded. Guidelines commentary that interprets or explains a guideline binds the federal courts unless it is unconstitutional, contrary to statute, or a plainly erroneous or inconsistent reading of the guideline. Why it still matters: Stinson is a leading statement of deference to an agency's interpretation of its own rules in the sentencing context, and it remains a touchstone as courts work out how much weight such interpretations carry after decisions like Kisor v. Wilkie narrowed that deference.
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