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Keywords

defendantappealtrialverdictpleabeyond a reasonable doubtjury trialguilty plea
defendantappealtrialverdictpleabeyond a reasonable doubtjury trialguilty plea

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Blakely v. Washington

Facts

Ralph Howard Blakely, Jr. was charged with first-degree kidnapping after abducting his estranged wife, Yolanda, and was later allowed to plead guilty to second-degree kidnapping. The trial court imposed a 90-month sentence, exceeding the standard maximum of 53 months, based on a judicial finding of deliberate cruelty. The judge's decision was based on additional facts that were not part of the guilty plea or determined by a jury.

Ralph Howard Blakely, Jr. was charged with first-degree kidnapping after abducting his estranged wife, Yolanda, and was later allowed to plead guilty to second-degree kidnapping. The trial court imposed a 90-month sentence, exceeding the standard maximum of 53 months, based on a judicial finding of deliberate cruelty. The judge's decision was based on additional facts that were not part of the guilty plea or determined by a jury.

Issue

Did the sentencing procedure violate the petitioner's Sixth Amendment right to a jury trial by allowing a judge to impose an exceptional sentence based on facts not found by a jury?

Did the sentencing procedure violate the petitioner's Sixth Amendment right to a jury trial by allowing a judge to impose an exceptional sentence based on facts not found by a jury?

Rule

Under the Sixth Amendment, 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.

Under the Sixth Amendment, 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 Court applied the rule from Apprendi v. New Jersey, determining that the statutory maximum for sentencing purposes is the maximum sentence a judge may impose based solely on the facts reflected in the jury verdict or admitted by the defendant. In this case, the judge's imposition of a 90-month sentence was based on additional facts not found by a jury, thus violating the petitioner's rights.

The Court applied the rule from Apprendi v. New Jersey, determining that the statutory maximum for sentencing purposes is the maximum sentence a judge may impose based solely on the facts reflected in the jury verdict or admitted by the defendant. In this case, the judge's imposition of a 90-month sentence was based on additional facts not found by a jury, thus violating the petitioner's rights.

Conclusion

The Supreme Court reversed the judgment of the Washington Court of Appeals and remanded the case for further proceedings, declaring the sentencing procedure unconstitutional.

The Supreme Court reversed the judgment of the Washington Court of Appeals and remanded the case for further proceedings, declaring the sentencing procedure unconstitutional.

Who won?

Petitioner, Ralph Howard Blakely, prevailed because the Supreme Court found that the sentencing procedure violated his Sixth Amendment rights.

Petitioner, Ralph Howard Blakely, prevailed because the Supreme Court found that the sentencing procedure violated his Sixth Amendment rights.

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