ALBERNAZ V. UNITED STATES 450 U.S. 333 (1981) CASE BRIEF

ALBERNAZ V. UNITED STATES
450 U.S. 333 (1981)
NATURE OF THE CASE: Albernaz el al (D) were convicted on separate counts of conspiracy to import marihuana, and conspiracy to distribute marihuana. D received consecutive sentences on each count, the length of each of their combined sentences exceeding the maximum which could have been imposed either for a conviction of conspiracy to import or for a conviction of conspiracy to distribute. The Court of Appeals affirmed the convictions and sentences.
FACTS: Ds were involved in an agreement, the objectives of which were to import marihuana and then to distribute it domestically. Ds were charged and convicted under two separate statutory provisions and received consecutive sentences. The length of each of their combined sentences exceeded the maximum 5-year sentence which could have been imposed either for a conviction of conspiracy to import or for a conviction of conspiracy to distribute. Ds appealed and the Court of Appeals affirmed. The Supreme Court granted certiorari. Ds contend it is not clear whether Congress intended to authorize multiple punishment for violation of the two statutes in question in a case involving only a single agreement or conspiracy, even though that isolated agreement had dual objectives. Ds went to invoke the rule of lenity and hold that the statutory ambiguity on this issue prevents the imposition of multiple punishment. Ds further contend that even if cumulative punishment was authorized by Congress, such punishment is barred by the Double Jeopardy Clause of the Fifth Amendment.

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