The guidelines were developed as a result of the Sentencing Reform Act of 1984, which aimed to address the problems of sentencing disparity, dishonesty, and, for some offenses, excessive leniency, all of which appeared to be worsened by a system of almost unlimited judicial discretion. The Commission presented the proposed guidelines to Congress in 1987. The guidelines have been criticized for failing to follow the systems already established in several States and for failing to present an ideal set of standards. However, these criticisms overlook the context in which the guidelines must operate and the political reality underlying the establishment of the Commission. The United States Supreme Court decision in Mistretta v. United States upheld the constitutionality of the guidelines, which are viewed by the Commission as initial standards that will be modified over time. 306 footnotes.