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Ralston v Robinson - Changing a Youth Corrections Act Sentence in Midstream

NCJ Number
Pace Law Review Volume: 3 Issue: 2 Dated: (Winter 1983) Pages: 375-393
R J Camera
Date Published
19 pages
In Ralston v. Robinson, the U.S. Supreme Court ignored the intent of the Federal Youth Corrections Act (YCA) and the well-stated common law rules in modifying the YCA treatment when it deemed such treatment futile.
In 1975, Robinson was found guilty of assaulting a Federal officer with a dangerous weapon. His conviction resulted in a 66-month adult sentence to run consecutively with the YCA sentence. In 1977, Robinson pleaded guilty to assaulting another Federal officer. For this offense, he received a 1-year sentence to run consecutively to his prior two sentences. After this second sentence, the Bureau of Prisons reclassified Robinson as an adult offender and no longer separated him from the adult prisoners. Robinson filed a writ of habeas corpus in U.S. district court, claiming that he was entitled under the YCA to be separated from adult prisoners. The district court granted the writ and the Seventh Circuit Court of Appeals affirmed. The U.S. Supreme Court reversed in Ralston v. Robinson, holding that the YCA permits sentencing judges great latitude in imposing sentences, and that a subsequent sentence can alter the original sentence by removing the offender from YCA treatment if such treatment will not benefit him further. The Court determined that continued YCA treatment for Robinson would be 'futile,' for Robinson had demonstrated that the treatment had little rehabilitative effect. However, as the dissent noted, such sentencing modification can lead to longer punishment than if the adult sentence were originally imposed. A total of 115 references are included.


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