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Keywords

defendantappealtrialbeyond a reasonable doubtaggravating circumstancesjury trial
defendanttrialbeyond a reasonable doubtjury trial

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Cunningham v. California, 549 U.S. 270, 127 S.Ct. 856, 166 L.Ed.2d 856, 75 USLW 4078, 07 Cal. Daily Op. Serv. 753, 2007 Daily Journal D.A.R. 1003, 20 Fla. L. Weekly Fed. S 67

Facts

Defendant John Cunningham was convicted of continuous sexual abuse of a child under 14 and sentenced to the upper term of 16 years under California's determinate sentencing law (DSL). The trial judge found six aggravating circumstances by a preponderance of the evidence, including the victim's vulnerability, and one mitigating factor, Cunningham's lack of prior criminal conduct. The California Court of Appeal affirmed the sentence, but the California Supreme Court denied review, leading to the Supreme Court's grant of certiorari.

Petitioner John Cunningham was tried and convicted of continuous sexual abuse of a child under the age of 14. Under the DSL, that offense is punishable by imprisonment for a lower term sentence of 6 years, a middle term sentence of 12 years, or an upper term sentence of 16 years.

Issue

Does California's determinate sentencing law, which allows a judge to find facts that expose a defendant to an elevated upper term sentence, violate the defendant's right to trial by jury as safeguarded by the Sixth and Fourteenth Amendments?

The question presented is whether the DSL, by placing sentence-elevating factfinding within the judge's province, violates a defendant's right to trial by jury safeguarded by the Sixth and Fourteenth Amendments.

Rule

Under the Sixth Amendment, any fact that increases a defendant's potential sentence beyond the statutory maximum must be found by a jury and proven beyond a reasonable doubt, not merely by a preponderance of the evidence.

Under the Sixth Amendment, any fact (other than a prior conviction) that exposes a defendant to a sentence in excess of the relevant statutory maximum must be found by a jury, not a judge, and established beyond a reasonable doubt, not merely by a preponderance of the evidence.

Analysis

The Court applied the rule established in Apprendi v. New Jersey, which requires that any fact increasing a sentence beyond the statutory maximum must be determined by a jury. The Court found that California's DSL violated this principle because it allowed a judge to impose an upper term sentence based on facts not found by a jury, thus infringing on the defendant's right to a jury trial.

Because aggravating facts that authorize the upper term are found by the judge, and need only be established by a preponderance of the evidence, the DSL violates the rule of Apprendi.

Conclusion

The Supreme Court reversed the California Court of Appeal's decision and remanded the case, holding that the DSL's judicial factfinding for sentence elevation violated the Sixth Amendment.

We hold that it does.

Who won?

Cunningham prevailed in the case because the Supreme Court found that his right to a jury trial was violated by the application of California's determinate sentencing law.

Cunningham prevailed in the case because the Supreme Court found that his right to a jury trial was violated by the application of California's determinate sentencing law.

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