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Amicus Briefs

U.S. v. Nasir

On December 1, 2020, the United States Court of Appeals for the Third Circuit, sitting en banc in United States v. Malik Nasir, rejected deference to the U.S. Sentencing Commission based on the Supreme Court’s decision last year in Kisor v. Wilkie, which “cut back on what had been understood to be uncritical and broad deference to agency interpretations.”

NCLA filed an amicus brief in the case, urging the federal court to re-examine the circuit’s treatment of “Stinson Deference.”  The 1993 Supreme Court decision, Stinson v. United States, commands federal judges to abandon their duty of independent judgment in violation of Article III and the judicial oath and to assign weight to a non-judicial entity’s interpretation of the law when imposing criminal sentences. It also raises serious due-process and separation-of-powers concerns when it causes courts to mandate judicial bias against a defendant, instead of lenity toward him.

Although the majority in the Third Circuit interpreted the text of the Guidelines in Mr. Nasir’s favor, Judge Stephen Bibas wrote separately to highlight the larger problems with Stinson deference that NLCA had raised in its amicus brief.  Judge Bibas agreed that the rule of lenity dictates that courts cannot defer to an agency’s interpretation of an ambiguous rule when doing so would increase a criminal penalty. In his powerful concurrence, Judge Bibas reasoned that “[w]hatever the virtues” of administrative deference may be, “those virtues cannot outweigh life and liberty” in criminal cases.

The Third Circuit is now part of a growing chorus of circuits correcting an erroneous and unconstitutional application of judicial deference.  NCLA has also helped convince the Sixth Circuit to limit its use of Stinson deference and has filed briefs with the United States Supreme Court in several challenging the failures of the Second, Eighth, and Tenth Circuits to revisit the issue in light of Kisor v. Wilkie.

Mark Chenoweth
President and Chief Legal Officer
Kara Rollins
Litigation Counsel
NCLA FILINGS

Opinion of the U.S. Court of Appeals for the Third Circuit

November 8, 2021 | Read More

Amicus Curiae Brief of the New Civil Liberties Alliance in Support of Malik Nasir

April 22, 2020 | Read More

PRESS RELEASES

Victory! NCLA Applauds Third Circ. for Rejecting Deference to US Sentencing Guidelines Commentary

December 1, 2020 | Read More

Two NCLA Amicus Briefs in Third and Tenth Circuits Challenge Judicial Deference to U.S. Sentencing Commission’s Guidelines Commentary

April 22, 2020 | Read More

IN THE MEDIA

Circulating Opinion

Washington Legal Foundation

February 8, 2023

En Banc Third Circuit Knocks the U.S. Sentencing Commission Down a Few Pegs

NCLA Blog

December 3, 2020

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