What is the current state of the law on sentencing of a person who has been convicted of a criminal offence but is illiterate?

More pertinent to our problem is the permissible use at sentencing of conditions affecting the defendant that could not be the basis for the imposition of penal sanctions. For example, sentencing judges frequently consider a defendant's addiction to narcotics or alcohol, though such a status cannot be the basis of a criminal conviction, see Robinson v. California, 370 U.S. 660, 82 S.Ct. 1417, 8 L.Ed.2d 758 (1962). A defendant's illiteracy or lack of job skills also illustrates the point. Though the rationale for reliance on such conditions in formulating a sentence are rarely articulated, it seems evident that the legitimacy of such considerations derives primarily from their relationship to the permissible sentencing objective of rehabilitation. Surely a sentence would encounter serious objections if it were enhanced because of addiction or illiteracy to achieve such sentencing objectives as retribution, denunciation, or specific or general deterrence. These sentencing objectives are generally thought to be permissible only with respect to conduct for which the defendant is blameworthy.