Harris: Mandatory Life Sentence Not Invalid under Alleyne

In U.S. v. Harris, No. 12-14482 (Jan. 28, 2014), the Court affirmed the mandatory life sentence of a defendant convicted of multiple Hobbs Act robberies and violations of 18 U.S.C. § 924(c), and sentenced pursuant to 18 U.S.C. § 3559(c). The Court rejected the argument that the mandatory life sentence was invalid in light of the Supreme Court’s recent decision in Alleyne. The Court pointed out that the mandatory life sentence was based on Harris’ prior convictions, and noted that Alleyne did not overrule Almendarez-Torres, which held that the Sixth Amendment did not require the fact of a prior conviction to be submitted to a jury. The Court also rejected a Separation of Powers challenge to the government’s authority to charge a defendant under § 3559(c) and 21 U.S.C. § 851 in a manner that triggers a mandatory minimum punishment of life.