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Keywords

defendantappealtrialverdictpleadivorcebeyond a reasonable doubtjury trialguilty plea
trialpleadivorcebeyond a reasonable doubtjury trialguilty plea

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Blakely v. Washington, 542 U.S. 296, 124 S.Ct. 2531, 159 L.Ed.2d 403, 72 USLW 4546, 04 Cal. Daily Op. Serv. 5539, 2004 Daily Journal D.A.R. 7581, 17 Fla. L. Weekly Fed. S 430, 6 A.L.R. Fed. 2d 619

Facts

Ralph Howard Blakely, Jr. was charged with second-degree kidnapping after he abducted his estranged wife, Yolanda, at knifepoint and forced her into a box in his truck. He was diagnosed with psychological disorders and had a tumultuous relationship with his wife, which led to her filing for divorce. Blakely pleaded guilty, which supported a maximum sentence of 53 months, but the judge imposed a 90-month sentence after finding he acted with 'deliberate cruelty,' a factor that justified an exceptional sentence under Washington law.

Petitioner married his wife Yolanda in 1973. He was evidently a difficult man to live with, having been diagnosed at various times with psychological and personality disorders including paranoid schizophrenia. His wife ultimately filed for divorce. In 1998, he abducted her from their orchard home in Grant County, Washington, binding her with duct tape and forcing her at knifepoint into a wooden box in the bed of his pickup truck.

Issue

Did the imposition of an exceptional sentence of 90 months, based on a judicial finding of 'deliberate cruelty,' violate Blakely's Sixth Amendment right to a jury trial?

Did the imposition of an exceptional sentence of 90 months, based on a judicial finding of 'deliberate cruelty,' violate Blakely's Sixth Amendment right to a jury trial?

Rule

Under the rule established in Apprendi v. New Jersey, any fact that increases the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury and proved beyond a reasonable doubt, except for the fact of a prior conviction.

This case requires the Court to apply the rule of Apprendi v. New Jersey, 530 U.S. 466, 490, 120 S.Ct. 2348, 147 L.Ed.2d 435, that, '[o]ther than the fact of a prior conviction, any fact that increases the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury, and proved beyond a reasonable doubt.'

Analysis

The Supreme Court analyzed whether the facts supporting Blakely's exceptional sentence were admitted by him or found by a jury. The Court concluded that the sentencing judge's finding of 'deliberate cruelty' was not based on facts admitted in the guilty plea, thus violating the Sixth Amendment. The Court emphasized that the statutory maximum for sentencing purposes is the maximum a judge may impose based solely on the facts reflected in the jury verdict or admitted by the defendant.

The judge in this case could not have imposed the exceptional 90–month sentence solely on the basis of the facts admitted in the guilty plea. Those facts alone were insufficient because, as the Washington Supreme Court has explained, '[a] reason offered to justify an exceptional sentence can be considered only if it takes into account factors other than those which are used in computing the standard range sentence for the offense.'

Conclusion

The Supreme Court reversed the Washington Court of Appeals' decision, holding that Blakely's exceptional sentence was invalid because it violated his Sixth Amendment rights.

Because the State's sentencing procedure did not comply with the Sixth Amendment, petitioner's sentence is invalid.

Who won?

Ralph Howard Blakely, Jr. prevailed in the case because the Supreme Court found that his Sixth Amendment right to a jury trial was violated by the imposition of an exceptional sentence based on facts not determined by a jury.

Ralph Howard Blakely, Jr. prevailed in the case because the Supreme Court found that his Sixth Amendment right to a jury trial was violated by the imposition of an exceptional sentence based on facts not determined by a jury.

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