He moved to have the United States Federal Sentencing Guidelines, which had been established under the Sentencing Reform Act of 1984, declared unconstitutional because it delegated excessive authority by Congress, resulting in a violation of separation of powers.
He aimed to invalidate the United States Federal Sentencing Guidelines, established in 1984 by the Sentencing Reform Act, as unconstitutional due to Congress transferring too much power, thereby infringing on the separation of powers.