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June 9, 2007

New DPIC report on doubts about the death penalty

The Death Penalty Information Center, as detailed here, has just released a new report entitled, "A Crisis of Confidence: American's Doubts About the Death Penalty."   The full report is available here, and this press release provides an overview:

Because of mistakes and a lack of efficacy, the death penalty is losing the confidence of the American public, according to a new poll by RT Strategies.... Almost 40% of the U.S. population believe they would be excluded as jurors in capital cases and a strong majority (58%) believe it is time for a moratorium on the death penalty while the process undergoes a careful review.  The poll was commissioned by the Death Penalty Information Center (DPIC).

Almost all Americans (87%) believe that an innocent person has already been executed in recent years, and over half (55%) say that fact has affected their views on the death penalty.  An overwhelming 69% of the public believes that reforms will not eliminate all wrongful convictions and executions.

June 9, 2007 in Death Penalty Reforms | Permalink | Comments (1) | TrackBack

All the sentencing news that's fit to print

The New York Times has a lot of sentencing coverage today.  Here are headlines and links:

June 9, 2007 in Recommended reading | Permalink | Comments (0) | TrackBack

June 8, 2007

More strong calls for justice for Genarlow Wilson

Because I was in Atlanta this morning for an Eleventh Circuit argument (reported by the media here and here), I saw the print copy of this extended editorial in the Atlanta Journal-Constitution entitled, "Teen's search for justice: Genarlow Wilson's 10-year sentence for consensual sex ought to be thrown out by judge."  TChris at TalkLeft here discusses the editorial and the fact that former President Jimmy Carter has spoken out in favor of justice for Genarlow.  A ruling on Wilson's state habeas action is expected on Monday.

Recent related posts:

June 8, 2007 in Examples of "over-punishment" | Permalink | Comments (1) | TrackBack

The latest news from Paris

I'm not sure whether I am still bemused or now getting fatigued by Parisian justice, but here is the latest development from the AP:

Paris Hilton was taken from a courtroom screaming and crying Friday seconds after a judge ordered her returned to jail to serve out her entire 45-day sentence for a parole violation in a reckless driving case. "It's not right!" shouted the weeping Hilton. "Mom!" she called out to her mother in the audience.

Hilton, who was brought to court in handcuffs in a sheriff's car, came into the courtroom disheveled and weeping. Her hair was askew and she wore a gray fuzzy sweatshirt over slacks.  She wore no makeup and she cried throughout the hearing.  Her body also shook constantly as she dabbed at her eyes....

California Attorney General Jerry Brown criticized the Sheriff's Department for letting Hilton out of jail, saying he believed she should serve out her sentence.  "It does hold up the system to ridicule when the powerful and the famous get special treatment," Brown told The Associated Press in an interview before testifying at a congressional hearing in Washington, D.C.  "I'm sure there's a lot of people who've seen their family members go to jail and have various ailments, physical and psychological, that didn't get them released," he said. "I'd say it's time for a course correction."

June 8, 2007 in Celebrity sentencings | Permalink | Comments (14) | TrackBack

Another former federal prosecutor suggests Libby's within-guideline sentence is unreasonable

As discussed here, former federal prosecutor Rudy Giuliani has already suggested that Lewis "Scooter" Libby's within-guideline sentence is substantively unreasonable.  Now I see from this Washington Post op-ed that former federal prosecutor William Otis, who advocates clemency for Libby, views Libby's within-guideline sentence as "excessive" and "unusually harsh" and "unnecessary."  Notably, Otis does not mention in his op-ed that Libby received a sentence at the bottom of the applicable guideline range.

Thankfully, Eric Muller, in this must-read post, effectively highlights the remarkable hypocrisy of these sentencing criticisms coming from Otis, who was not long ago a spokesman for the Justice Department decrying judicial decisions to sentence below the guidelines.  Here is one of the points Otis made in testimony to Congress complaining about sentences below the guidelines: "Even more than others, persons convicted of criminal behavior need — for their own good and ours — to turn away from the culture of grievance-building and excuse-making and join the culture of personal responsibility."

In addition, given his experience with guideline sentencing realities, Otis should know better than to call Libby's sentence "unusually harsh."  As I have highlighted in posts here and here and here, decorated veteran Victor Rita received a within-guideline 33-month sentence for far less serious instances of perjury and obstruction.  And yet, I do not believe that Otis has spoken out in support of Rita's appeal of his sentence to the Supreme Court.

I hope that the Justices considering Rita's appeal are taking note of how these "tough on crime" former federal prosecutors now are so ready to spotlight that the guidelines can sometimes produce unreasonably harsh sentence ranges.

Some recent related posts:

June 8, 2007 in Libby sentencing | Permalink | Comments (30) | TrackBack

The Paris jail saga continues ... and raises equal justice concerns

As this AP article details, only a matter of hours "after Paris Hilton was sent home under house arrest Thursday, the judge who put her in jail for violating her reckless-driving probation ordered her into court to determine whether she should be put back behind bars."

I'm not sure I have enough energy or interest to come up with any thoughtful commentary on this latest development in the Paris debacle.  Fortunately, Laura Appleman at PrawfsBlawg and Jeralyn at TalkLeft have smart things to say about all the Hilton brouhaha.

UPDATE:  Hilton's early release seems to be the top story on all the morning talk shows, and the focus is justifiably turning to whether any other jail inmate could have be reassigned to home confinement based on the "medical conditions" cited as the reason for Hilton's release.  (My favorite sound-bite: "Paris is going from the big house to the really big house."). 

Here is the start of a telling commentary from John Gibson at Fox News, entitled "Al Sharpton is Right about Paris Hilton":

Today when Paris Hilton got sprung from jail 20 days early — from a sentence that was just half of what was originally imposed — the story turned out to be that Paris' shrink went to the jailers and said she was about to have a nervous breakdown.  So they let her go home early with an ankle bracelet.  Sharpton immediately said there may have been racism involved here.

Look, when he's right he's right.  No matter what you think of Rev. Al, it is hard to imagine that anywhere in America a black woman is getting out of jail today because her shrink says she's about to have a nervous breakdown.  He says it wouldn't happen, and I agree.

It shouldn't happen either.  It shouldn't happen with "little miss just anybody," whether she's African-American or white or Asian or Hispanic or anything. And it shouldn't have happened with Paris Hilton.

June 8, 2007 in Celebrity sentencings | Permalink | Comments (5) | TrackBack

June 7, 2007

Putting sentencing theories into practice

This extended article in the Daily Report, the local legal paper, explains at length why I am now in Atlanta gearing up for an oral argument tomorrow.  In addition, I just noticed today this AP article discussing the honorable veteran who also ended up as one of my clients.

Though I am obviously keeping busy, I am sure learning a lot about the realities of modern federal sentencing practices.  I suppose I am doing a job job taking to heart Neal Katyal's terrifically interesting Harvard Law Review comment encouraging the legal academy to go practice.

June 7, 2007 in Booker in the Circuits | Permalink | Comments (3) | TrackBack

More Libby lessons as pardons and clemency are considered

There are so many insights and lessons one can draw from the sentencing of Lewis Libby.  Prior posts here and here focused on some guideline lessons, and this fine new Los Angeles Times piece focuses on lessons about the sentencing judge.  And, of course, the focal point for future insights and lessons will center on the Presideny's pardon and clemency power.

This New York Times piece provides a good overview of some pardon issues in the Libby case, and Margaret Love says so much in this short LA Times op-ed entitled "Begging Bush's pardon."  Here is the start of Love's very strong commentary:

As speculation grows about whether President Bush will pardon I. Lewis "Scooter" Libby, or at least commute his prison sentence, it's important to remember the hundreds of ordinary people who have been patiently standing in line, some for many years, waiting for presidential forgiveness.  In a sense, it is these largely anonymous applicants for executive clemency (of which pardon and commutation are subsets) who hold the key to the president's ability to help the well-connected Mr. Libby.

This is not so much a matter of fairness as it is of political common sense.  Many of those with pending applications for clemency were convicted long ago of garden-variety crimes and have fully served their time; many others are still serving lengthy mandatory prison terms from which there is no hope of parole (parole having been eliminated from federal sentencing).

One such applicant is my client, Willie Mays Aikens, whose addiction to crack cocaine ruined a brilliant major league baseball career and who is now in the 13th year of a 20-year prison term for selling drugs to an undercover policewoman — an extraordinarily harsh sentence for a relatively minor, nonviolent drug offense.  There are countless others in similar positions.  If the president is unwilling to look favorably on deserving applicants for clemency like Aikens, how can he justify helping Libby? ...

Bush has been more sparing in his exercise of the constitutional pardon power than any president in the last 100 years, including his father. He has pardoned only 113 people in more than six years in office and denied more than 1,000 pardon applications.  He has granted only three of more than 5,000 requests for sentence reduction from federal prisoners.  Many hundreds of applications remain to be acted on....

For a president who has been willing to stretch his other constitutional powers to the limit and beyond, Bush has proved strangely hesitant to exercise the one power that is unquestionably his alone.... The federal pardon power has a proud history, yet in recent years it has been trivialized and allowed to atrophy.  The Libby case presents Bush with an opportunity to change that.

If he begins now to exercise his pardon power with more intention and greater liberality, with more sympathy for human error and less aversion to controversy, there is at least a chance that the public will regard with equanimity any relief he ultimately chooses to grant to Scooter Libby.

Some related posts:

June 7, 2007 in Libby sentencing | Permalink | Comments (6) | TrackBack

Paris Hilton released early from jail based on "medical considerations"

As detailed in this CNN article, "Paris Hilton was let out of jail Thursday morning, days after she began serving what was to have been a 45-day sentence for violating probation, a spokesman for the Los Angeles County Sheriff's Department said."  Here are more specifics:

Hilton must wear a monitoring bracelet and remain at her home for another 40 days, said sheriff's department spokesman Steve Whitmore.  Medical considerations "played a part" in the decision to offer Hilton home confinement for the remainder of her sentence, Whitmore said.

He said privacy rules prohibited him from giving details about the medical issues, but celebrity Web site TMZ.com earlier quoted sources saying Hilton was refusing to eat much of the jail food served her.

Whitmore said that after "extensive consultation with medical personnel" it was decided to offer Hilton "reassignment" to home confinement, which she and her attorneys accepted.

The questions this news prompts are nearly endless:

June 7, 2007 in Celebrity sentencings | Permalink | Comments (13) | TrackBack

Advocacy against sex offender residency restrictions

Among a lot of great new stuff at the blogs Sex Crimes and Sex Offender Issues are posts here and here and here setting out advocacy and arguments against sex offender residency restrictions.  Of particular note, and worthy of a full read, is this amicus brief filed in the Ohio Supreme Court in a case challenging the application of Ohio's residency restriction.  Here is part of the brief's argument summary:

Research has shown that sex offenders with stable housing and social support are much less likely to commit new sex offenses compared to those offenders who lack stability. Residence restrictions deprive sex offenders of stable housing and social support, and thus significantly increase the risk of recidivism.  In addition, sex offenders who become homeless, or fail to provide accurate addresses as a result of these restrictions, will be more difficult to supervise and monitor in the community, thereby increasing the risk to children.  Recent studies have concluded that sex offender residence statutes create a false sense of security that may leave children more vulnerable to sexual abuse.

Equally troubling is the lack of evidence that these laws actually protect children.  To the contrary, those states that have studied the issue carefully have found no relationship between sex offense recidivism and the proximity of sex offenders' residences to schools or other places where children congregate.

In reality, sex offender residence laws in Ohio and elsewhere around the country are driven by fear, not facts.  Despite widespread belief that sex offender recidivism rates are high, recent studies have shown that such recidivism is the exception, rather than the rule, particularly if the offender has received treatment. In cases where recidivism did occur, residence restrictions had no impact.  Instead, efforts to enforce sex offender residence laws drain valuable law enforcement resources.

Some related posts on sex offender residency restrictions:

June 7, 2007 in Sex Offender Sentencing | Permalink | Comments (53) | TrackBack

Dissecting the key guideline calculation in the Libby sentencing

Though talk is already turning to pardons in the wake of Lewis Libby's sentencing, I am very pleased to see that Edward Lazarus in this very effective FindLaw column is looking more closely at the key guideline determination that led Judge Walton to give Libby a sentencing of 30 months.  Here are snippets from the column:

Amid the[] politically-driven reactions, it is worth pausing to consider the Sentencing Guidelines calculation that led to Libby's sentence.  When the issue is viewed through this admittedly narrow and incomplete prism, I would argue that Libby's 30-month sentence is justifiable, but that a more lenient outcome would also have been appropriate....

Under the Guidelines, the offense severity for someone convicted of perjury or obstruction is the greater of either the severity rating for generic perjury/obstruction, or the severity rating of the offense being lied about or covered up. In essence, the Guidelines treat someone guilty of perjury or obstruction as an accessory after the fact to the offense underlying the lies and obstruction.  Some thoughtful commentators have started complaining about the fairness of this approach. But as a general matter, it makes very good sense. Not all lies are created equal. The reason for the lie ought to matter....

Moving from the general to the specific, Libby's case presents a close question for whether cross-referencing the underlying offense being investigated, for purposes of Guidelines calculations, makes sense. Here, Libby himself was not charged with violating the IIPA or the Espionage Act and, perhaps even more important, neither was anyone else.  A reasonable argument can be made that cross-referencing doesn't make much sense when it may well be the case that no one actually committed the crimes being investigated.

Is it really fair, after all, to up Libby's punishment for obstructing an investigation in which there was no underlying crime charged (or perhaps even committed)?

Some related posts:

June 7, 2007 in Libby sentencing | Permalink | Comments (8) | TrackBack

Should there be a registry for domestic violence offenders?

Thanks to this post at Crime & Consequences, I see from this local news article that Pennsylvania legislators are considering a bill to create a registry and database of persons convicted of a domestic violence offense.  Here are more details from the article:

Two years after a man shot his wife and later killed himself in Quakertown, officials in the Upper Bucks borough will likely urge commonwealth legislators to create a state-wide Internet registry of domestic violence offenders to help prevent such tragedies from happening again. Borough council expects to approve a resolution tonight calling on the Legislature to pass a bill known as "Robin's Law."

Introduced in the state House on May 31, the bill would create a Megan's Law-style database. Instead of sexual predators though, the picture, address and crime of domestic violence convicts will be posted online for anyone to see, according to a preliminary draft of the bill.

Though I have not seen much firm empirical evidence, I have heard lots of anecdotal reports from various sources that sex offender registries can be a helpful and effective law enforcement tool.  If this is true, my first instinct is to support broader use of offender registries.

June 7, 2007 in Criminal Sentences Alternatives | Permalink | Comments (9) | TrackBack

California sentencing commission closer to reality

As detailed in articles from the San Jose Mercury News and the Sacramento Bee, both houses of the California legislature passed (slightly different) bills to create a sentencing commission in California.  the Mercury News article nicely details differences in the bill and the partisan political rhetoric surrounding their consideration and passage.

Some related posts:

June 7, 2007 in State Sentencing Guidelines | Permalink | Comments (0) | TrackBack

A legal eulogy for the Claiborne case

The St. Louis Post-Dispatch has this new article, entitled "Death leads to dismissal of key Supreme Court case," that discusses the legal aftermation of the death of Mario Claiborne.  Here are excerpts:

Investigators are still sorting out why Mario Claiborne was following a stolen pickup last week and just how the pursuit led to gunfire and Claiborne's death.  But the killing has created other legal twists, as it forced the dismissal of Claiborne's closely watched case before the U.S. Supreme Court, which was expected to rule within the next few weeks. J ustices were to clarify how much discretion federal judges have when applying sentencing guidelines....

Claiborne's case already had traveled an improbable road by reaching the Supreme Court, where oral arguments were held in February.  Thousands of people seek review by the high court and few succeed. And of those who get the court's attention, even fewer are killed before their case is heard.  "Once people make it to the Supreme Court, we don't tend to lose them," said Tom Goldstein, who heads the Supreme Court practice of Washington law firm Akin Gump Strauss Hauer & Feld.

The case had been watched across the country and potentially could have affected thousands of criminal defendants and a growing backlog of cases awaiting resolution of the issue.  About 9,800 of the more than 70,000 defendants sentenced in federal court in fiscal year 2006 got similar departures from guideline sentences, according to Justice Department statistics.  "You've got a lot of different parties that see this as having a far-reaching effect," [Assistant U.S. Attorney Cris] Stevens said.

Some related posts:

June 7, 2007 in Claiborne and Rita reasonableness case | Permalink | Comments (3) | TrackBack

June 6, 2007

Another remarkable homage to jury trial rights from Judge Young

In June 2004, about a week before the Supreme Court decided Blakely, District Judge William Young of the District of Massachusetts issued this remarkable 174-page opinion in US v. Green concluding that the logic of Apprendi and Ring rendered the federal sentencing guidelines unconstitutional.  (Of course, the Supreme Court vindicated Judge Young's analysis through its subsequent opinions in Blakely and Booker.)  Last summer, Judge Young today issued this remarkable 141-page opinion in US v. Kandirakis to explain his view of post-Booker sentencing realities.

Today, Judge Young has completed his third extraordinary opinion spotlighting the importance of jury trial rights and the Apprendi line of cases system through an opinion in US v. Griffin, No. 05-10372 (D. Mass. June 6, 2007) (available for download below).  Though weighing in at a svelte 45 pages, Griffin is jam packed with amazing insights and rhetorical flourishes (as well as a cite to Orin Kerr's favorite recent casenote). 

Of particular importance, Griffin give punch to the Supreme Court's ruling in Cunningham (even though most other federal courts have opted to ignore Cunnigham's potential import).  Let me quote one of the many major passages from Griffin:

In short, the importance of Cunningham is two-fold.  First, much as a codicil is to a revoked will, Cunningham's timing -- after the internally irreconcilable Booker decisions -- republishes the Apprendi/Blakely/Constitutional Booker theme over Remedial Booker's minimization of the Sixth Amendment.  Thus, the epicenter of Sixth Amendment jurisprudence for sentencing purposes is located on the facts found by a jury beyond a reasonable doubt.  See Cunningham, 127 S.Ct. at 863-64. Second, the analysis in Cunningham reiterates and clarifies that the "statutory maximum" for Sixth Amendment analysis must be determined, in first instance, by jury-found facts. See id. at 868. For these two purposes, it makes no difference that Cunningham focuses on a state sentencing law instead of the federal advisory sentencing guidelines.

Download judge_young_griffin_opinion.rtf

June 6, 2007 in Booker in district courts | Permalink | Comments (2) | TrackBack

The SCOTUS death divide

Mark Sherman has today filed this effective AP story, entitled "4 Justices Often Side With the Condemned."  Here is a snippet:

No one on the Supreme Court publicly opposes the death penalty, but four justices often side with death row inmates who are fighting to avoid execution.  Though they are a minority on the nine-justice court, Justices Stephen Breyer, Ruth Bader Ginsburg, David Souter and John Paul Stevens win as often as they lose....

The court has been implacably split on this issue, as on others.  Roberts typically has been aligned with Justices Samuel Alito, Antonin Scalia and Clarence Thomas, opting to defer to the state courts that imposed and upheld death sentences....

"In the late '80s and early '90s, you were a rare defendant who won a death penalty case at the Supreme Court," said Richard Dieter, executive director of the anti-capital punishment Death Penalty Information Center. "Now there's a fair chance that if you can get Justice Kennedy, you'll win."

June 6, 2007 in Death Penalty Reforms | Permalink | Comments (0) | TrackBack

LA Times opposes death penalty for child rape for intriguing reason

Yesterday's Los Angeles Times had this interesting editorial, entitled "Death to child rapists?  The Louisiana Supreme Court thinks child rapists should be executed.  Might the U.S. Supreme Court agree?".  Here are snippets:

The United States is virtually alone among advanced democracies in permitting capital punishment. But widespread ambivalence about imposing the ultimate penalty has produced a minor industry of litigation that has had the effect of postponing executions for years and even decades.  This state of affairs, which frustrates supporters and opponents of capital punishment, exists even though the death penalty has been imposed for more than a generation only in murder cases.  Now imagine how clogged the courts would become if states were allowed to execute individuals for other crimes....

The rape of a child is an unspeakable crime.  In its decision, the Louisiana court wrote that "short of first-degree murder, we can think of no other non-homicide crime more deserving" of the death penalty.  But imaginative state legislators might easily discover other offenses worthy of the ultimate punishment: terrorism, major drug dealing (a capital offense under federal law) or violent hate crimes.  Capital punishment has proved dysfunctional and divisive as a sanction for murder.  The U.S. Supreme Court shouldn't compound the error — and increase its own workload — by allowing states to execute criminals who do not take a human life.

I find quite interesting and compelling the notion that allowing the death penalty for non-homicide crimes is a recipe for lots and lots and lots and lots of litigation (especially in the Ninth Circuit).  But is this sound pragmatic concern a valid constitutional consideration for the Supreme Court interpreting the Eighth Amendment? 

In other words, I think the LA Times has a winning argument here, but its pragmatic advocacy against any new non-homicide capital offenses ought to be directed to Congress and state legislators, not to the US Supreme Court.

June 6, 2007 in Death Penalty Reforms, Sex Offender Sentencing | Permalink | Comments (6) | TrackBack

Fascinating Second Circuit case reversing above-guideline sentence

The Second Circuit today in US v. Cavera, No. 05-4591 (2d Cir. June 6, 2007) (available here), issues a lengthy ruling — with a notable concurrence from one of my former bosses — on post-Booker sentencing standards.  Here is how it begins:

This appeal prompts us to write further on the subject of federal criminal sentencing in the aftermath of United States v. Booker, 543 U.S. 220 (2005). All agree that Booker removed the mandatory teeth of the United States Sentencing Guidelines (Guidelines) by rendering them advisory, and that Justice Breyer's remedy opinion put some bite back into the Guidelines by requiring courts when sentencing defendants to "consider" them.  See id. at 259-60.  We, like our sister circuits, are still putting flesh on the skeleton issue of what it means to consider the Guidelines, and -- as we address specifically in this case -- when and under what circumstances a district court may impose a non-Guidelines sentence.

Among many interesting aspects of Cavera is that it was argued way back in May 2006.  I have an inkling that this ruling was being held pending a Supreme Court decision in Claiborne.  But now that it is unclear, after Claiborne's dismissal, whether and how the Supreme Court will addresses reasonableness review for non-guidelines sentence, the panel in Cavera perhaps sensibly figured it needed finally to resolve this appeal ASAP.

UPDATE:  This post provides a nice long write-up about Cavera at the Second Circuit Sentencing Blog.

MORE: The New York Law Journal has coverage of Cavera that's right now available at this link.

June 6, 2007 in Booker in the Circuits | Permalink | Comments (0) | TrackBack

Genarlow Wilson state habeas appeal update

A scheduled hearing on Genarlow Wilson's state habeas action has the Atlanta Journal-Constitution again discussing this remarkable case with this article, entitled "Sex landed him in prison; will petition bail him out?", and this op-ed by columnist Cynthia Tucker, entitled "Genarlow Wilson should be free."  For a lot more background, check out these prior posts about the case:

UPDATE:  This AP story provides a brief account of the argument in the Wilson case today, but it has no information about whether and when a ruling on the merits might be forthcoming.

MORE:  This updated AP piece indicates that the state judge "says he'll make a decision by Monday in the case of a Georgia man who was sentenced to 10 years in prison for having consensual oral sex with a 15-year-old when he was two years older than she was."

June 6, 2007 in Examples of "over-punishment" | Permalink | Comments (2) | TrackBack

Rudy Giuliani suggests Libby's within-guideline sentence is unreasonable

As regular readers know, despite thousands of post-Booker appeals, the federal circuit courts are yet to find a single within-guideline sentence to be substantively unreasonable.  However, thanks to a question during the Republican debate asking the candidates about pardoning Scooter Libby, it now appears that former federal prosecutor Rudy Giuliani has concluded that Lewis Libby's within-guideline sentence is substantively unreasonable.  Here is exactly what Giuliani said during the debate:

I think the sentence was way out of line.  I mean, the sentence was grossly excessive in a situation in which at the beginning, the prosecutor knew who the leak was and he knew a crime wasn't committed. I recommended over a thousand pardons to President Reagan when I was associate attorney general. I would see if it fit the criteria for pardon. I'd wait for the appeal. I think what the judge did today argues more in favor of a pardon because this is excessive punishment.

Though Giuliani does not use the term "unreasonable," that seems to be the obvious legal implication from Giuliani's description of Libby's within-guideline sentence as "way out of line" and "grossly excessive."  I wonder if Giuliani would use the same description for Victor Rita's 33-month sentence for less serious instances of perjury and obstruction.  Of course, the Fourth Circuit found Rita's sentence to be reasonable; under current DC Circuit law, Libby's 30-month sentence is already presumptively reasonable.

For additional great guideline lessons from the Libby sentencing, be sure to check out Ellen Podgor's thoughtful commentary here at the White Collar Crime Prof Blog.

June 6, 2007 in Libby sentencing | Permalink | Comments (8) | TrackBack