In U.S. v. Heath, No. 05-10175 (Aug. 12, 2005), the Court held that a sentencing court violated Article III when, as a condiction of Heath’s supervised release, it delegated to a probation officer the power to decide whether Heath had to participate in a mental health treatment program.
The Court found that the Article III violation met all four prongs of the "plain error" test. The error was "plain" under the Court’s precedent, and the decisions in other circuits, which held that requiring a defendant to participate in a mental health program is "unquestionably a judicial function." The error affected Heath’s substantial rights because absent the error, the district court, not the probation office, would have decided whether to incorporate mental health treatment in his sentence. "The fate of a defendant must rest with the district court, not the probation office." Finally the error seriously affects the fairness, integrity or public reputation of judicial proceedings.
The Court rejected Heath’s argument that the district court had no authority to commit him, noting that probationers are often subject to limitations to which ordinary citizens are free.
