United States v. Haymond

Andre Ralph Haymond was convicted of possessing child pornography and sentenced to prison followed by supervised release. While on supervised release, he was again found to possess child pornography. Under 18 U.S.C. § 3583(k), the judge revoked his supervised release and imposed a mandatory minimum five-year prison term based on a preponderance of the evidence, without a jury finding. Haymond challenged the constitutionality of the statute, arguing it violated his Fifth and Sixth Amendment rights. The case reached the Supreme Court, which examined whether the provision allowed a judge, rather than a jury, to find facts that trigger a new mandatory prison sentence, bypassing the traditional reasonable doubt standard required for criminal punishment.

The Supreme Court held that 18 U.S.C. § 3583(k) is unconstitutional. A plurality of the Court found that the provision deprived Haymond of his right to a jury trial because it allowed a judge, rather than a jury, to find facts that increase the mandatory minimum punishment based on a mere preponderance of the evidence. The judgment of the Tenth Circuit was affirmed, and the case was remanded for further proceedings.

Whether 18 U.S.C. § 3583(k), which requires a mandatory minimum five-year prison term upon a judge’s finding by a preponderance of the evidence that a sex offender on supervised release committed certain new crimes, violates the Fifth and Sixth Amendment rights to due process and a jury trial.

The decision limits Congress’s ability to bypass jury trial rights in supervised release revocation proceedings. It reinforces the principle that any fact triggering a new and significant mandatory prison sentence must be proved to a jury beyond a reasonable doubt. The ruling has implications for future legislative efforts to impose mandatory penalties outside traditional criminal prosecution, and it safeguards constitutional protections for individuals on supervised release.