June 17, 2013
US Supreme Court - June 17, 2013
Alleyne v. US - 6th Amendment - Apprendi - Mandatory Minimums - Jury Trial
Facts: A jury convicted Mr. Alleyne of robbery without finding Mr. Alleyne branshied a firearm. Not to worry, the other prosecutor in criminal cases, the judge, unceremoniously found Mr. Alleyne brandished the firearm. According to the decision, Mr. Alleyne’s accomplice brandished the gun. A finding that Mr. Alleyne brandished the firearm raised the mandatory minimum from 5 years to 7 years in prison.
Issue: Whether the trial court violated Mr. Allenyne's 6th Amendment right to a jury trial by increasing the mandatory minimum of his sentence by two years without a jury finding?
Reasoning: In a majority opinion, Justice Thomas, the truest believer in the Right to a Jury Trial, wrote, “The essential point is that the aggravating fact produced a higher range, which, in turn, conclusively indicates that the fact is an element of a distinct and aggravated crime. It must, therefore, be submitted to the jury and found beyond a reasonable doubt. Because there is no basis in principle or logic to dis-tinguish facts that raise the maximum from those that increase the minimum, Harris was inconsistent with Apprendi. It is, accordingly, overruled.”