Yes, it violates his rights. The Court said the Sixth Amendment right to a jury trial means a jury must decide on any fact that changes the legal punishment for a crime. It doesn't matter if the fact raises the 'ceiling' (the maximum sentence) or the 'floor' (the minimum sentence). Since making the minimum sentence longer is a big change in punishment, the jury has to be the one to decide if the fact that triggers it is true.

No, it doesn't violate his rights. The jury already found Alleyne guilty, which meant his sentence could be anywhere from five years to life. The judge was just working inside that range. A law that sets a higher minimum based on a fact like 'brandishing' just guides the judge's decision; it doesn't overstep the jury. The jury's job is to set the big-picture boundaries, not to control every detail of the final sentence.

No, and the Court shouldn't have changed its mind. This judge argued that the Court should stick with its previous decision on this exact issue (a principle called 'stare decisis'). He thought it was wrong to throw out an established rule just because the judges on the Court had changed. He argued that the old rule was fine and that the Court was creating instability in the law by flip-flopping.

Yes, the jury has to decide any fact that makes the minimum punishment higher. The earlier Harris case was wrong to say judges could decide those facts. The Constitution gives people the right to have a jury decide all the facts that affect their punishment. It's not fair to have a judge add years to someone's jail time based on facts the jury didn't find. Showing the gun in a scary way is a separate, worse crime that the jury has to agree happened. There's no good reason to treat facts that raise the maximum punishment differently than facts that raise the minimum. Harris made a mistake, so the Court is overruling it.

Agrees with the main opinion. Says the Court should usually stick with what it decided before, but sometimes there are special reasons to change course. Argues this is one of those times because the Harris case doesn't fit with other recent decisions on jury rights, stands out as the only case saying judges can find facts to raise minimum sentences, and isn't the kind of rule people have relied on too heavily. Says overruling Harris is necessary to fix the Court's messy law in this area.

Agrees Harris should be overruled even though he disagreed with Apprendi. Thinks the law needs to be consistent - it doesn't make sense to require juries to find facts that raise maximum sentences but not minimums. Says getting rid of the difference between Harris and Apprendi will fix the problem.

Disagrees with overruling Harris. Argues the Constitution doesn't require juries to find facts that raise minimum sentences. Says the Court is taking power away from legislatures and giving it to judges, not protecting defendants. Believes the jury authorized the judge to give the sentence he did for the reason he did, so Alleyne's jury rights weren't violated.

Criticizes the Court for too easily overruling Harris and not respecting its own precedents. Suggests that if the Court is willing to overrule cases here, maybe it should consider overruling Apprendi too since Alito thinks it was wrongly decided. Worries the Court is setting a bad example that will cause more overruling of precedent in the future. Argues that if the Court can overrule Harris just because a majority disagrees with it now, it could do the same to Apprendi or even to this case someday.

The Alleyne Court held that any fact that increases the mandatory minimum sentence for a crime is an element that must be submitted to the jury and found beyond a reasonable doubt.

In Alleyne, the Supreme Court held that "facts that increase mandatory minimum sentences must be submitted to the jury."

This right, in conjunction with the Due Process Clause, requires that each of the material elements of a crime be proved to a jury beyond a reasonable doubt.

In Alleyne, the Supreme Court determined that this principle applies not only to facts that increase the applicable maximum sentence but also to facts that increase the applicable mandatory minimum sentence.

—any fact that "aggravates the legally prescribed range of allowable sentences" for a crime is an "element" that must be submitted to a jury.

The Michigan Supreme Court in Lockridge held that Michigan's sentencing scheme violates the Sixth Amendment right to a jury trial because it requires "judicial fact-finding beyond facts admitted by the defendant or found by the jury to score offense variables (OVs) that mandatorily increase the floor of the guidelines minimum sentence range, ie, the `mandatory …

Yes. A judicial finding of a fact that increases a mandatory minimum sentence violates the Sixth Amendment right to a jury trial. The Court extended the rule from Apprendi v. New Jersey, which held that facts increasing the maximum sentence are elements of the offense, to also include facts that increase the mandatory minimum sentence. The Court reasoned that there is no principled distinction between a fact that increases the statutory maximum (the ceiling) and one that increases the statutory minimum (the floor), as both alter the prescribed range of penalties and aggravate the punishment. By increasing the floor, the fact alters the legally prescribed punishment and thus constitutes an element of a separate, aggravated offense. Therefore, such facts must be found by a jury beyond a reasonable doubt. This decision overrules Harris v. United States.

No. A judicial finding of a fact that increases a mandatory minimum sentence does not violate the Sixth Amendment. The dissent argued that the jury's verdict authorized a sentencing range of five years to life, and the judge's finding of brandishing simply limited the judge's discretion within that pre-authorized range. The Sixth Amendment protects the jury's role to determine the facts that set the maximum possible punishment, but it does not prevent the legislature from guiding judicial discretion within that range. The jury's role is to act as a barrier between the defendant and the State, not between the judge and the legislature. Because the judge could have imposed the seven-year sentence even without the mandatory minimum based on the jury's verdict, the judicial fact-finding did not infringe on the jury's province.

No. This dissent primarily argued that the Court should have adhered to the principle of stare decisis and upheld the precedent set in Harris v. United States and McMillan v. Pennsylvania. Justice Alito contended that the Court overruled a well-entrenched precedent without sufficient justification. He suggested that if the Court were to reconsider precedents in this area, the foundational case of Apprendi v. New Jersey would be a better candidate, as its historical analysis is questionable. The dissent expressed concern that overruling Harris simply because a new majority disagrees with it sets a poor 'precedent about precedent'.

Yes. Any fact that increases the mandatory minimum sentence for a crime is an 'element' that must be submitted to the jury and found beyond a reasonable doubt. This includes facts that increase the applicable mandatory minimum sentence, as they aggravate the legally prescribed range of allowable sentences. Harris v. United States, which held that judicial factfinding that increases the mandatory minimum sentence is permissible under the Sixth Amendment, is overruled. The Sixth Amendment provides defendants with the right to have a jury find those facts beyond a reasonable doubt. While Harris declined to extend Apprendi v. New Jersey to facts increasing mandatory minimum sentences, the principle applied in Apprendi applies with equal force to facts increasing the mandatory minimum. It is impossible to dissociate the floor of a sentencing range from the penalty affixed to the crime, and it is impossible to dispute that facts increasing the legally prescribed floor aggravate the punishment. Defining facts that increase a mandatory statutory minimum to be part of the substantive offense enables the defendant to predict the legally applicable penalty from the face of the indictment and preserves the historic role of the jury. Elevating the low-end of a sentencing range heightens the loss of liberty associated with the crime and aggravates the punishment, so facts increasing the mandatory minimum sentence are elements of a separate, aggravated offense that must be found by the jury. Because there is no basis in principle or logic to distinguish facts that raise the maximum from those that increase the minimum, Harris was inconsistent with Apprendi and is overruled.

Concurs with the majority opinion and emphasizes the importance of stare decisis principles. Explains that establishing that a decision was wrong does not alone justify overruling it, but notes that stare decisis is not an 'inexorable command.' Argues that a special justification is present here to overrule Harris v. United States because (1) its holding has been undermined by subsequent Sixth Amendment decisions like Apprendi v. New Jersey, (2) it represents an outlier in the Court's Sixth Amendment jurisprudence, and (3) the reliance interests are not as strong as in other cases. Contends that overruling Harris is necessary to bring coherence and consistency to the Court's Sixth Amendment law.

Agrees that Harris v. United States should be overruled and that Apprendi v. New Jersey's basic jury-determination rule should apply to mandatory minimum sentences. Explains that he continues to disagree with Apprendi but believes the law should no longer tolerate the anomaly created by the distinction between Harris and Apprendi. Argues that Apprendi's rule should apply to both facts that increase the statutory maximum and the statutory minimum because it is highly anomalous to have a jury requirement for facts that permit a higher sentence but not for facts that require a higher sentence. Believes that overruling Harris would erase this anomaly.

Disagrees with the majority's decision to overrule Harris v. United States and to apply Apprendi v. New Jersey to mandatory minimum sentences. Argues that the majority's rule, which requires any fact that increases the mandatory minimum sentence to be found by a jury, has no basis in the Constitution's text, history, or purpose. Contends that the Sixth Amendment does not limit legislatures' ability to establish mandatory minimum sentences based on judicial factfinding. Asserts that the majority transforms the right to a jury trial into a protection for judges from the power of the legislature, rather than a protection for defendants from the power of the government. Believes that the jury's verdict authorized the judge to impose the sentence he did for the factual reason he did, so the Sixth Amendment was not violated in this case.

Criticizes the majority for too readily overruling Harris v. United States and for not adhering to stare decisis principles. Suggests that if the Court is willing to overrule precedent in this case, it should also consider overruling Apprendi v. New Jersey, which Alito believes was wrongly decided. Argues that the Court's decision creates a troubling precedent about precedent that may have greater effect than the questionable decisions on which it relies. Contends that if Harris and McMillan v. Pennsylvania can be overruled simply because a majority of the Court now disagrees with them, the same approach could be taken in future cases to overrule Apprendi and Alleyne itself.

Alleyne v. United States

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