Tampa Criminal Lawyer Blog
Federal sentencing laws impose strict limits on the types and lengths of punishment courts may impose, even when the facts of a case are particularly egregious. A recent Florida decision issued in a violent crime case reaffirms the non-waivable nature of statutory maximum penalties and emphasizes the principle that sentencing authority is confined by congressional mandate, as the court vacated a 15-year term of supervised release, finding that the district court exceeded its statutory authority, even though the defendant purportedly “stipulated” to the excessive term. If you are accused of a violent crime, it is smart to speak to a Tampa violent crime defense lawyer about what measures you can take to protect your interests.
History of the Case
It is alleged that the defendant engaged in a violent campaign of crimes against gay men in Miami while on probation. Reportedly, the defendant used a dating app to lure victims under false pretenses. On multiple occasions, the defendant brandished a firearm, forced victims into vehicles, and drove them to banks or stores to withdraw money or buy gift cards. Allegedly, the crimes escalated to physical assault, with one victim being beaten and another shot multiple times. The defendant reportedly made hateful, homophobic statements to his victims and expressed an intent to punish them for their sexual orientation.
It is reported that a federal grand jury indicted the defendant on 17 counts, including carjacking, kidnapping, brandishing, and discharging a firearm in furtherance of a crime of violence and bank robbery. The defendant pleaded guilty to all charges without a plea agreement.
Allegedly, the presentence investigation report determined that the guideline imprisonment range was a life based on the severity of the crimes and the defendant’s criminal history. The report also noted that under federal law, the maximum term of supervised release for the offenses charged was five years since concurrent terms are required by statute. Nonetheless, during the sentencing hearing, the district court proposed what it viewed as a sentencing compromise: reduce the prison term from life to 45 years, provided that the defendant agreed to a 15-year term of supervised release, triple the maximum permitted by law.
It is reported that the defendant’s counsel stated they would agree to this increased term. Despite the government’s objection and warning that a 15-year term would exceed the statutory cap, the court imposed 45 years in prison followed by 15 years of supervised release. The court noted that it had accepted the illegal term as a basis for reducing the length of incarceration. The government appealed.
Grounds for Vacating Sentences
On appeal, the court reviewed the legality of the sentence de novo. The core question was whether a defendant may validly waive a statutory maximum penalty, specifically, the five-year cap on supervised release set forth in 18 U.S.C. § 3583(b) for Class A and B felonies.
The court held that the defendant’s stipulation to a 15-year term was legally ineffective because statutory maximums are not waivable. Unlike rights that belong to the defendant personally, such as the right to counsel or the right against self-incrimination, statutory maximums are jurisdictional boundaries established by Congress. The court emphasized that “[s]tatutory maximums are not ‘rights.’ They are limits imposed by Congress on the punishment a court may impose.”
The court reiterated that an illegal sentence is one that exceeds the statutory authority of the sentencing court. The panel further noted that no legal precedent supports the notion that a defendant may waive such a statutory limit, particularly when doing so expands the court’s jurisdiction or sentencing power.
The court rejected the defendant’s reliance on the invited-error doctrine, which ordinarily prevents a party from challenging an error that it induced at trial on appeal. Because the government, not the defendant—was appealing the sentence, the doctrine did not apply.
The court concluded that the 15-year supervised release term was illegal and vacated the entire sentence. The court explained that sentencing is an interdependent “package” and that altering one component, such as supervised release, requires the court to revisit the entire sentence. Because the original sentence was expressly conditioned on the excessive supervised release term, the appellate court remanded the case for a full resentencing, allowing the district court to reconsider all aspects of the sentence within the legal framework established by Congress.
Consult an Experienced Tampa Violent Crime Defense Attorney Today
Courts are bound by statutory limits and even seemingly agreed-upon terms can be overturned on appeal if they exceed congressional authority. If you are facing federal charges, including those involving violent offenses, it is critical to work with defense counsel who understands both trial strategy and the intricacies of federal sentencing law. At Hanlon Law, our Tampa violent crime defense attorneys are committed to delivering rigorous advocacy and safeguarding your rights. Call our office at 813-435-6200 or fill out our online form to schedule a consultation.