U.S. Supreme Court: Sentences Cannot be Increased Because of Rehabilitation

• Tapia v. United States

The United States Supreme Court recently held that drug rehabilitation is no longer an appropriate reason for a longer prison sentence. Tapia was given a longer sentence because the Judge wanted to recommend her for the 500-hour drug treatment program offered in U.S. Prisons. The Judge believed Tapia would have a better chance to get into the program if she had a longer sentence, but he could not guarantee Tapia a spot in the program.

Tapia argued that section 3582(a) of the Sentencing Reform Act (SRA) precludes Judges from considering rehabilitation as a factor when deciding the length of a prison sentence. 3582(a) states:

"The Court, in determining whether to impose a term of imprisonment, and, if a term of imprisonment is to be imposed, in determining the length of the term, shall consider the factors set forth in section 3553(a) to the extent that they are applicable, recognizing that imprisonment is not an appropriate means of promoting correction and rehabilitation."

The Court looked to the plain meaning of the statute to determine Congress' intent. They began by stating that the definition of "recognize" is "to acknowledge or treat as valid" and that the definition of "appropriate" is something that is "suitable or fitting for a particular purpose". Given these definitions, the Court reasoned that Congress would have them interpret this section as meaning, "that the courts should acknowledge that imprisonment is not suitable for the purpose of rehabilitation."

With this interpretation of the statute, the Court held that rehabilitation is not an appropriate reason to impose a longer prison sentence. The Court also noted that if Congress had intended on allowing courts to use rehabilitation as a reason for a longer prison sentence, they would have provided the courts with the authority to ensure those defendants a spot in the 500-hour drug program. Since Congress has not granted this authority, the plain meaning of the statute precludes judges from imposing longer prison sentences because of rehabilitation.