Buford v. United States

In Buford v. United States, 532 U.S. 59, 121 S.Ct. 1276, 149 L.Ed.2d 197 (2001), the Supreme Court addressed the standard that a court of appeals should apply in reviewing a district court's determination that an offender's prior convictions were "functionally consolidated," or "related," for purposes of sentencing. In concluding that deferential review was appropriate, the Court focused on the "relative institutional advantages enjoyed by the district court in making the type of determination at issue." Id. at 64, 121 S.Ct. 1276. It reasoned that a district court was in a better position to decide whether various convictions were related, and thus should be consolidated, in part because the district court saw many more consolidations. Id. The Court observed, further, that "factual nuance may closely guide the legal decision" of whether to consolidate convictions, "with legal results depending heavily upon an understanding of the significance of case-specific details." Id. at 65, 121 S.Ct. 1276. Finally, the Court found significant that the question before it was not a "generally recurring, purely legal matter, such as interpreting a set of legal words, say, those of an individual guideline, in order to determine their basic intent," which a court of appeals may be better suited to answer and would thus warrant less deferential review. Id. "Rather, the question at issue grows out of, and is bounded by, case-specific detailed factual circumstances," which "limits the value of appellate court precedent" because the next court to consider the issue will have a different set of facts before it. Id. at 65-66, 121 S.Ct. 1276. These considerations, the Court concluded, weighed in favor of deferential review.