| Litigants: | United States v. Cotton |
| Arguedate: | April 15 |
| Argueyear: | 2002 |
| Decidedate: | May 20 |
| Decideyear: | 2002 |
| Fullname: | United States v. Leonard Cotton, et al. |
| Usvol: | 535 |
| Uspage: | 625 |
| Docket: | 01-687 |
| Oralargument: | https://apps.oyez.org/player/#/rehnquist10/oral_argument_audio/21803 |
| Opinionannouncement: | https://apps.oyez.org/player/#/rehnquist10/opinion_announcement_audio/22228 |
| Holding: | The court held that the omission from a federal indictment of a fact that enhances the statutory maximum sentence does not justify a Court of Appeals' vacating the enhanced sentence even if the defendant offered no objection at the trial court |
| Majority: | Rehnquist |
| Joinmajority: | unanimous |
| Lawsapplied: | Controlled Substances Act |
| Overturned Previous Case: | Ex parte Bain (1887) |
United States v. Cotton, 535 U.S. 625 (2002), is a United States Supreme Court case that held the omission of a fact in a federal indictment that would enhance the maximum sentence is not a jurisdictional error and thus is not justification for a vacation of the sentence.
Leonard Cotton was a drug dealer from Baltimore, Maryland who was charged by a federal grand jury with conspiracy to possess and conspiracy to possess with intent to distribute crack cocaine. The prosecution did not state the quantity of drugs in the indictment, however the court later found Cotton responsible for 1.5kg (03.3lb) of cocaine.[1]
Under federal sentencing guidelines, the maximum sentence for a conviction without a specified quantity is twenty years imprisonment. The Court of Appeals vacated the sentence on the grounds of a jurisdictional error by the amounts not being included in the grand jury indictments.
The United States was represented by Deputy Solicitor General Michael Dreeben.[2]
The court ruled unanimously 9-0 in favour of the United States. The opinion read as follows:This ruling in part overturned Ex parte Bain, 121 U.S 1 (1887).[3]