Background
Jonathon Del Smith pleaded guilty to illegally possessing firearms in violation of federal law. He had a prior Idaho felony conviction involving injury to a child and was sentenced to thirty months in federal prison to run consecutively to his state sentence. The district court also ordered Smith to undergo a psychosexual evaluation while incarcerated.
The court’s reasoning
The court held that district courts do not have the authority to order the Bureau of Prisons to place a defendant at a particular facility or to dictate treatment programs, citing Tapia versus United States. The court found no abuse of discretion in the district court’s sentencing decision, noting that the court considered relevant factors including the defendant’s age, background, and criminal history.
District courts do not have the authority to order the BOP, as part of a defendant’s sentence of imprisonment, to place a defendant at a particular prison or to dictate the treatment programs in which a defendant may participate.
Tapia v. United States, 564 U.S. 319, 330–31 (2011)
What it means going forward
Sentencing courts must recommend rather than mandate specific prison placements or treatment programs, preserving the Bureau of Prisons’ discretion over inmate classification and programming.