Apprendi v. New Jersey

Jump to content

From Wikipedia, the free encyclopedia

This article has multiple issues. Please help **improve it ** or discuss these issues on the **talk page **. (Learn how and when to remove these messages )

(Learn how and when to remove this message )

2000 United States Supreme Court case

Apprendi v. New Jersey, 530 U.S. 466 (2000), is a landmark United States Supreme Court decision with regard to aggravating factors in crimes. The Court ruled that the Sixth Amendment right to a jury trial , incorporated against the states through the Fourteenth Amendment , prohibited judges from enhancing criminal sentences beyond statutory maxima based on facts other than those decided by the jury beyond a reasonable doubt . The decision has been a cornerstone in the modern resurgence in jury trial rights. As Justice Scalia noted in his concurring opinion, the jury-trial right "has never been efficient; but it has always been free."

The Apprendi decision was subsequently cited as precedent by the court in its consideration of _Ring v. Arizona _ (2002), which struck down Arizona 's judge-only method of imposing the death penalty , and also in _Blakely v. Washington _ (2004), which ruled that mandatory state sentencing guidelines are the statutory maximum for purposes of applying the Apprendi rule.

Background

[(https://en.wikipedia.org/w/index.php?title=Apprendi_v._New_Jersey&action=edit&section=1 "Edit section: Background")
]

In the early morning hours of December 22, 1994, Charles Apprendi Jr., fired several .22-caliber bullets into the home of an African-American family that had recently moved into his neighborhood. He was arrested an hour later. During questioning by police, he admitted that he shot at the house because its occupants were "black in color" and for that reason he did not "want them in the neighborhood."

Later, Apprendi pleaded guilty to weapons possession charges. Each of these counts carried a sentence of between 5 and 10 years in prison. As part of the plea bargain, the prosecution reserved the right to seek an enhanced sentence on the basis that the crime was committed with a biased purpose. Such an enhancement would have doubled the sentence otherwise imposed for each of the crimes. Apprendi, in turn, reserved the right to challenge the bias crime enhancement, claiming it violated the federal Constitution .

The trial judge accepted Apprendi's plea. At a later hearing, he heard testimony from Apprendi himself as well as from psychologists stating that the shooting was not motivated by racial hatred but instead was the result of intoxication. The policeman testified at this hearing that Apprendi's motivation was racial animus. The trial judge found "by a preponderance of the evidence" that Apprendi's crime was motivated by the race of the victims. He sentenced Apprendi to 12 years in prison—2 years above the maximum sentence authorized for the weapons charge apart from the race enhancement.

Apprendi appealed, represented by Charles Coant and Joseph O'Neill. The Appellate Division of the New Jersey Superior Court affirmed the enhancement on the grounds that it was a "sentencing factor" rather than an "element" of the crime, and therefore not subject to the jury-trial and proof-beyond-a-reasonable-doubt requirements of the Constitution. The New Jersey Supreme Court agreed with this conclusion, and also affirmed Apprendi's sentence. Apprendi appealed to the Supreme Court.

Opinion of the Court

[(https://en.wikipedia.org/w/index.php?title=Apprendi_v._New_Jersey&action=edit&section=2 "Edit section: Opinion of the Court")
]

Apprendi shifted the landscape with regard to the findings that comprise a criminal sentence. "Other 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." In this case, the hate-crime enhancement was determined by a judge, sitting alone, and subjected to a lower standard of proof — a preponderance of the evidence, instead of beyond a reasonable doubt. Because of the enhancement, the judge imposed a 12-year sentence, which was 2 years greater than the 10-year sentence otherwise authorized by the findings at the plea hearing. Under the rule the Court formulated, Apprendi's case had to be sent back to the New Jersey courts.

Historical basis

[(https://en.wikipedia.org/w/index.php?title=Apprendi_v._New_Jersey&action=edit&section=3 "Edit section: Historical basis")
]

Oliver Wendell Holmes observed, "The law threatens certain pains if you do certain things, intending thereby to give you a new motive for not doing them. If you persist in doing them, it has to inflict the pains in order that its threats may continue to be believed." Here, New Jersey threatened punishment for infractions against its firearms laws, and additional punishment for violations of its hate-crimes laws. Due process procedural safeguards should apply equally to both of these punishments.

Under the Constitution, due process gives criminal defendants two interdependent procedural safeguards with respect to the manner in which the sentence is determined. The first of these is the jury trial, a "guard against a spirit of oppression and tyranny on the part of the rulers" and "the great bulwark of our civil and political liberties," whereby "the truth of every accusation, whether preferred in the shape of indictment, information, or appeal, should afterwards be confirmed by the unanimous suffrage of twelve of the defendant's equals and neighbors." The second is proof beyond a reasonable doubt, the historical "measure of persuasion by which the prosecution must convince the trier of all the essential elements of guilt." There was historically no distinction between an "element" of a crime and a "sentencing factor" because the trial judge had very little discretion at sentencing, because most crimes had a specific sentence attached to them.

Justice Thomas explained how the original understanding of the jury-trial requirement supported the Court's ruling. He also argued that the jury-trial requirement applied to both mandatory minimum sentences and the findings of prior convictions used to enhance sentences. To make this argument, Justice Thomas had to repudiate his prior support for the prior conviction exception crafted in _Almendarez-Torres v. United States _, 523 U.S. 224 (1998). "What matters is the way by which a fact enters into the sentence." Even though a prior conviction may be valid because it entailed its own jury trial, the fact that that prior conviction was being used to enhance a new sentence meant that that fact must be submitted to a jury again.

20th-century developments

[(https://en.wikipedia.org/w/index.php?title=Apprendi_v._New_Jersey&action=edit&section=4 "Edit section: 20th-century developments")
]

In _Williams v. New York _, 337 U.S. 241 (1949), the Court affirmed that a sentencing judge has discretion to impose any sentence authorized by statute in an individual case. This statement accommodated a shift in the way legislatures had set punishments between the 18th and 20th centuries — a shift away from fixed punishments and toward broader and broader ranges of punishment. This was not to say that "trial practices cannot change in the course of centuries and still remain true to the principles that emerged from the Framers' fears that the jury right could be lost not only by gross denial, but by erosion." Nevertheless, practice should at least adhere to basic principles, even as that practice evolves over the course of time.

With the decision in _In re Winship _ in 1970, the Court expressly said for the first time that due process demands from the government proof beyond a reasonable doubt of every element of a crime. Thus, the Court held that a state court could not force a defendant to prove he did not act with malice aforethought in order to avoid a murder conviction, as in _Mullaney v. Wilbur _, 421 U.S. 684 (1975). Criminal law "is concerned not only with guilt or innocence in the abstract, but also with the degree of criminal culpability assessed" in the defendant. Thus, redefining the elements of murder to make the level of intent required bear on punishment was not an appropriate method for avoiding the reasonable-doubt requirement of the Constitution.

It was not until 1986, in _McMillan v. Pennsylvania _, 477 [U.S.](https://en.wikipedia.org/wiki/United_St

…