## Facts

- Alejandra Tapia was convicted in federal district court of smuggling unauthorized aliens into the United States for financial gain and other offenses.
- At sentencing, the district judge imposed a 51-month prison term.
- The judge stated that the prison term was selected to be long enough for Tapia to qualify for and complete the Bureau of Prisons’ Residential Drug Abuse Program (RDAP).
- Tapia appealed, arguing that the court improperly based the length of imprisonment on rehabilitation considerations, contrary to 18 U.S.C. § 3582(a).
- The Ninth Circuit affirmed, reasoning that while a court may not impose prison to rehabilitate, it may consider rehabilitation needs when setting the length once imprisonment is chosen.
- The Supreme Court granted certiorari to resolve a circuit split on whether rehabilitation may be considered in determining the length of a prison term.

## Issues

1. Whether 18 U.S.C. § 3582(a) prohibits a federal court from imposing or lengthening a term of imprisonment in order to promote a defendant’s rehabilitation, including to facilitate eligibility for and completion of programs such as RDAP.

## Decision

- The Supreme Court unanimously reversed the Ninth Circuit.
- The Court held that § 3582(a) does not permit a sentencing court to impose or lengthen a prison term to promote rehabilitation.
- The case was remanded for further proceedings, including consideration of the effect of Tapia’s failure to object at sentencing on the applicable standard of review.

## Legal Principles

- Under 18 U.S.C. § 3582(a), sentencing courts must recognize that imprisonment is not an appropriate means of promoting correction and rehabilitation when deciding whether to impose imprisonment and when determining its length.
- A court may not impose or increase a prison term to make a defendant eligible for, or able to complete, rehabilitative treatment while incarcerated.
- Rehabilitation may be addressed through recommendations to the Bureau of Prisons and through noncustodial sentencing components (such as probation or supervised release), but it cannot justify the length of imprisonment.
- The Sentencing Reform Act’s structure, including 28 U.S.C. § 994(k), reflects Congress’s rejection of using incarceration terms as a tool for rehabilitation.

## Conclusion

The Court held that federal sentencing law forbids using rehabilitation as a reason to impose or lengthen imprisonment, reversing a sentence potentially extended to enable participation in RDAP and remanding for the lower court to address preservation and review issues.


Tapia v. United States, 564 U.S. 319 (2011)