17 June 2013

Law in Plain English: Alleyne v. United States

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

Alleyne v. United States

Generally, issues of fact are decided by juries and issues of law are decided by judges. So in a previous decision (Apprendi v. New Jersey), the Supreme Court ruled that the right to a jury trial guarantees that any fact that leads to a sentence longer than the maximum provided by law must be found by the jury, applying the standard of beyond a reasonable doubt. Nevertheless, in a different decision (Harris v. United States), the Court held that the Constitution does not require facts which increase a mandatory minimum sentence to be determined by a jury. Alleyne was tried and convicted for 1) robbery affecting commerce and 2) use or carry of a firearm during and in relation to a crime of violence, both federal crimes. At sentencing, the district judge held him responsible for brandishing a firearm, despite the fact that the jury did not find him guilty of brandishing. This finding elevated Alleyne's mandatory minimum sentence for the firearm conviction from five to seven years. The question before the Court was whether the decision in Harris should be overruled. In a larger sense, the question for the Court was how far to extend Apprendi. In a 5-4 decision, the Supreme Court ruled that because mandatory minimum sentences increase the penalty for a crime, any fact that increases the mandatory minimum is an “element” that must be submitted to the jury. As a result, Harris is overruled. The practical impact of this decision is that Apprendi, which held that any fact that leads to a sentence longer than the maximum provided by law must be found by the jury, now extends to facts which increase a mandatory minimum sentence.
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