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For more than two decades, Congress has been on a mission to obtain uniformity in the federal sentencing system. What began with the Sentencing Reform Act of 1984 ("SRA"), and was soon followed by the Sentencing Guidelines, has been continually criticized by both the judiciary and the legislature.' In the spring of 2003, in what caught many interested parties off guard, Congress abruptly responded to the perceived inadequacies of the federal sentencing system by enacting the Feeney Amendment to the PROTECT Act ("The Prosecutorial Remedies and Tools Against the Exploitation of Children Today Act of 2003"), signed into law by President Bush on April 30, 2003.2 The Act implemented sweeping reforms focused on eliminating trial judges' discretion to deviate from congressionally mandated sentences.3

Sentencing Reform Lessons: From the Sentencing Reform Act of 1984 to the Feeney Amendment