Blakely v. Washington
542 U.S. 296 (2004)
Rule of Law:
The Sixth Amendment right to a jury trial requires that any fact, other than a prior conviction, that increases the penalty for a crime beyond the prescribed "statutory maximum" must be submitted to a jury and proved beyond a reasonable doubt. The "statutory maximum" for this purpose is the maximum sentence a judge may impose based solely on the facts reflected in the jury verdict or admitted by the defendant.
Facts:
- Petitioner Ralph Howard Blakely, Jr., was married to Yolanda Blakely, who filed for divorce.
- In 1998, Blakely abducted his wife from their home in Grant County, Washington.
- He bound her with duct tape, forced her at knifepoint into a wooden box in his pickup truck, and implored her to dismiss the divorce suit.
- Blakely ordered their 13-year-old son, Ralphy, to follow them in another car, threatening to harm Yolanda with a shotgun if he did not comply.
- Ralphy escaped at a gas station and sought help.
- Blakely continued with Yolanda to a friend's house in Montana, where he was arrested after the friend called the police.
Procedural Posture:
- The State of Washington charged Ralph Howard Blakely, Jr., with first-degree kidnaping in a state trial court.
- Blakely entered a plea agreement, pleading guilty to the reduced charges of second-degree kidnaping involving domestic violence and use of a firearm.
- The plea subjected Blakely to a standard sentencing range of 49 to 53 months.
- Following a three-day bench hearing, the trial judge found that Blakely had acted with 'deliberate cruelty,' an aggravating factor under state law.
- The judge imposed an 'exceptional sentence' of 90 months, 37 months above the standard range maximum.
- Blakely, as appellant, appealed to the Washington Court of Appeals, arguing the sentence violated his Sixth Amendment right to a jury trial.
- The Court of Appeals affirmed the trial court's sentence.
- The Washington Supreme Court denied discretionary review.
- The U.S. Supreme Court granted certiorari to review the case.
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Issue:
Does a state's determinate sentencing scheme, which allows a judge to impose a sentence above the standard guideline range based on facts found by the judge but not admitted by the defendant or found by a jury, violate the defendant's Sixth Amendment right to a trial by jury?
Opinions:
Majority - Justice Scalia
Yes. A sentencing scheme that allows a judge to impose a penalty greater than the maximum authorized by the facts found by a jury or admitted by the defendant violates the Sixth Amendment right to a jury trial. The relevant 'statutory maximum' is not the absolute maximum penalty for the crime class, but the maximum sentence within the standard range that a judge can impose without any additional factual findings. In this case, the standard range maxed out at 53 months based on the facts Blakely admitted in his plea. The judge's subsequent finding of 'deliberate cruelty' was a factual determination that increased the legally authorized sentence to 90 months. Because this fact was neither admitted by Blakely nor proved to a jury beyond a reasonable doubt, the sentence is unconstitutional.
Dissenting - Justice O’Connor
No. The Court's decision will have the disastrous effect of dismantling over 20 years of sentencing reform designed to bring uniformity and reduce judicial discretion. The Washington guidelines scheme constrained, rather than expanded, judicial power compared to older, indeterminate sentencing systems. The 'statutory maximum' should be understood as the absolute legislative ceiling for the offense (10 years in this case), and a judge's fact-finding within that range to apply guidelines does not usurp the jury's role. This formalistic rule will lead to greater sentencing disparities and undermine the laudable goals of state and federal sentencing guidelines.
Dissenting - Justice Kennedy
No. The majority's decision disregards the fundamental principle of constructive dialogue between the judicial and legislative branches that has led to valuable reforms like sentencing guidelines. Sentencing reform is a prime example of a collaborative process where legislatures codify the shared experiences of judges and other participants to correct systemic problems. The Court's rigid ruling shuts down this productive interchange and undermines the ability of states to serve as laboratories for innovation in the administration of criminal justice.
Dissenting - Justice Breyer
No. The majority's holding is based on a flawed analysis that will lead to impractical and unfair consequences for the criminal justice system. Legislatures will be forced to choose between three bad options: 1) a rigid 'charge offense' system that gives prosecutors immense power, 2) a return to the chaotic disparities of indeterminate sentencing, or 3) a costly and complex system of bifurcated jury trials. The decision will embed plea bargaining, weaken the link between real conduct and real punishment, and ultimately harm the very fairness principles the Court purports to protect.
Analysis:
Blakely v. Washington was a landmark decision that dramatically expanded the scope of the Apprendi rule and invalidated numerous state determinate sentencing schemes. By narrowly defining 'statutory maximum' as the top of the standard guideline range, the Court made it unconstitutional for judges to find aggravating facts to justify an upward departure. This decision threw the entire system of sentencing guidelines into question, directly leading to the Court's subsequent ruling in United States v. Booker, which held the mandatory Federal Sentencing Guidelines unconstitutional and rendered them advisory. Blakely fundamentally shifted power in sentencing from judges to juries and prosecutors, reshaping modern criminal procedure.
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