Blakely v. Washington

2004

Court: US Supreme Court

Facts: Blakely pleaded guilty to kidnapping his estranged wife. He's a troubled guy, with verious psychological diagnoses. She wanted a divorce, and he captured her, duct-taped her, and forced her into a box in his truck at knife-point. Ralphy, their son, called the cops after some driving around.

Posture: Charged with kidnapping, pled guilty, sentenced to a term beyond the maximum carried by the facts he admitted, on the basis of a finding of "deliberate cruelty" by the judge. Appeal.

Issue: Does sentencing on the basis of facts found by a judge violate 6A right to trial by jury?

Holding: Yes.

Rule: Apprendi applies to facts pled as well as facts in evidence.

Reasoning: The right to a jury trial would be hollow if it didn't mean that the state was required to prove specific things before punishing you. 6A is not a limitation of judicial power; it is a reservation of jury power.

Dicta: Dissent: determinate sentencing schemes involve fact-finding by judges, but have less discretion than indeterminate sentencing schemes. So if the latter is constitutional, so is the former.