Braxton v. United States

Defendant shot at his own door after United States Marshals attempted to enter his home to arrest him. As a result, the Defendant was charged with (1) an attempt to kill a deputy United States Marshal, (2) assault on a deputy marshal, and (3) the use of a firearm during a crime of violence. The Defendant pled guilty to the assault and firearm charges but pled not guilty to the attempted murder charge. The Defendant did not have a plea agreement with the Government. The Defendant was sentenced under the Federal Sentencing Guidelines as if he had been convicted of the attempted murder charge. The court relied on § 1B1.2(a) of the Guidelines to justify its sentencing decision, which states that “in the case of a plea of guilty… containing a stipulation that specifically establishes a more serious offense than the offense of conviction, [the court shall apply the guideline] most applicable to the stipulated offense.” The Defendant appealed, arguing that § 1B1.2(a) only applied if there was a stipulation produced as part of a formal plea agreement, while the Government argued that the language of the statute did not limit the application of § 1B1.2(a) to such stipulations. Instead, the Government argued that any plea that contained a stipulation was covered by § 1B1.2(a). The Supreme Court did not address these arguments, an issue in which the federal circuit courts were split. The Court based its decision to not address the arguments on the fact that the Sentencing Commission had announced plans to address the issue and eliminate the circuit split. In turning to the specific facts of the Defendant’s case, the Court found that the Defendant did not stipulate a fact that specifically established that he attempted to murder any of the Marshals that entered his home. The Court reversed the rulings below.

“With respect to federal law apart from the Constitution, we are not the sole body that c[an] eliminate [] conflicts, at least as far as their continuation into the future is concerned. Obviously, Congress itself can eliminate a conflict concerning a statutory provision by making a clarifying amendment to the statute, and agencies can do the same with respect to regulations.” p.347-348