Hutto v. Davis
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454 U.S. 370 (1982)
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U.S. Supreme Court
Hutto v. Davis, 454 U.S. 370 (1982)
Hutto v. Davis
Decided January 11, 1982
454 U.S. 370
Respondent was convicted in a Virginia state court of possessing with intent to distribute and distribution of nine ounces of marihuana, and was sentenced to 40 years in prison as authorized by Virginia law. After exhausting direct appeal, respondent brought an action in Federal District Court seeking a writ of habeas corpus on the ground that the 40-year sentence was so grossly disproportionate to the crime that it constituted cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. The District Court issued the writ, and, ultimately, the Court of Appeals affirmed, after its prior affirmance had been vacated by this Court and the case had been remanded for reconsideration in light of Rummel v. Estelle, 445 U. S. 263.
Held: By affirming the District Court's decision after this Court's decision in Rummel, supra -- which stands for the proposition that federal courts should be reluctant to review legislatively mandated prison terms, and successful challenges to the proportionality of particular sentences should be exceedingly rare -- the Court of Appeals sanctioned an intrusion into the basic line-drawing process that is properly within the province of legislatures, not courts. More importantly, the Court of Appeals ignored the hierarchy of the federal court system created by the Constitution and Congress.
Certiorari granted; 646 F.2d 123, reversed and remanded.