Fair warning in sentencing
Engstrom v. United States
In brief
- Where it stands
- Dismissed
Petition denied.
- What it’s about
- Paul Engstrom asked whether the rule requiring fair warning before courts expand criminal laws also applies to sentence calculations, and whether an appeals court may find a sentencing error to be plain error without considering the test’s fourth step.
- Who it affects
- The denial ends Engstrom’s request for Supreme Court review but leaves both legal questions unanswered in this proceeding.
Summary: written with AI from the case record.
What it's about
The Supreme Court refused to hear his case (denied review) and did not decide either question.
The questions arose from the Ninth Circuit’s review of Engstrom’s sentence and focused on how courts interpret criminal laws and check sentencing mistakes.
Question presented
1. In Bouie v. City of Columbia , 378 U.S. 347 (1964), this Court recognized a right of fair warning against an unforeseeable and retroactive judicial expansion of a criminal statute. Is that right limited exclusively to cases concerning the scope of criminal liability, or does it include cases involving the calculation of a defendant’s sentence? 2. In Olano v. United States , 507 U.S. 725 (1993), this Court set out the four prongs of analysis for plain-error review. Where a district court’s error results in a sentence that the court would not have otherwise imposed, may the appellate court find plain-error review satisfied without considering Olano ’s fourth prong?
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Brief added: Petition
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.