Publication Date


Document Type

Survey Article


Despite the passage of almost two decades since the enactment of the United States Sentencing Guidelines ("U.S.S.G."), issues relating to the sentencing guidelines continue to dominate Eleventh Circuit case law. This is no doubt due, at least in part, to the fact that by 2003, the guidelines had been amended 662 times.

Ambiguities within the guidelines regularly lead to differing interpretations of those guidelines among the circuit courts of appeals. These differing interpretations result in further guideline amendments aimed at reconciling the splits among the circuits. The amended guidelines result in new issues of first impression, new interpretations, and new splits among the circuits. The guidelines are amended again, and the cycle continues.

The year 2003 was just another chapter in this continuing saga. The United States Court of Appeals for the Eleventh Circuit was confronted with several issues of first impression that related in large part to guideline amendments. Many of the amendments became effective in 2001 but did not begin to surface in reported decisions until 2003.