In Dorsey v. United States the Court held that provisions of Sentencing Reform Act, which increase the amounts of crack cocaine required to trigger mandatory minimum sentences are applicable to offenses committed after the date the act was passed, but before the act’s effective date. The act was intended to reduce the disparity in sentencing for offenses involving crack rocks, and offenses involving powder cocaine. Justice Breyer wrote:
Until 2010, the relevant statute imposed upon an offender who dealt in powder cocaine the same sentence it imposed upon an offender who dealt in one one-hundredth that amount of crack cocaine. It imposed, for example, the same 5-year minimum term upon (1) an offender convicted of possessing with intent to distribute 500 grams of powder cocaine as upon (2) an offender convicted of possessing with intent to distribute 5 grams of crack.
During the years since the implementation of the sentencing guidelines, the law enforcement community and others strongly criticized Congress’ decision to set the crack-to-powder mandatory minimum ratio at 100-to-1.
The court relied heavily on statutory interpretation in crafting its opinion, but discussion of these techniques is beyond the scope of this blog.