Gall v. United States
Supreme Court
552 U.S. 38 (2007)
Gall (defendant) participated in a drug distribution operation for about six months in college, voluntarily withdrew, later voluntarily admitted his limited role to federal agents when questioned, turned himself in after being indicted 18 months later, and in the meantime built a legitimate construction business while out on bail; the Sentencing Guidelines recommended a minimum 30-month prison sentence, but after a full sentencing hearing considering Gall's conduct and testimony, the district judge instead imposed 36 months of probation. The court of appeals, applying a proportionality test from its own prior precedent requiring extraordinary justification for a substantial guidelines departure, reversed and remanded for resentencing, and Gall sought Supreme Court review.
Whether appellate courts must apply a deferential abuse-of-discretion standard, rather than a heightened proportionality test requiring extraordinary justification, when reviewing a district court's sentence that departs substantially from the Sentencing Guidelines.