Cases decided by the U.S. Supreme Court typically cut a wide swath of relevance and applicability, and a 5-4 Court ruling issued this Monday that addressed mandatory minimum sentencing is certainly no different.
In summary, the Court engaged in a major sentencing reform by overruling a decade-old case it had authored in 2002 and recommitted to what one commentator termed “a straightforward but hard-fought extension of the so-called Apprendi rule.”
That rule, which was enunciated in a 2000 Supreme Court case, essentially states that the jury in a trial — not the judge — presides over any fact that carries the potential for increasing punishment for a defendant. Any such fact is an element of the crime that, for punishment to be increased, must be proved beyond a reasonable doubt. The Sixth Amendment right to a jury trial requires that.
In its 2002 decision, though (Harris v. United States), the Court said that such a required finding did not apply where mandatory minimum sentencing floors were concerned. Those could be triggered by a judge’s determination of a fact based on a lower “preponderance of the evidence” standard. For years, judges have been deemed to have no discretion in avoiding imposition of a higher sentence when that threshold proof standard has been met.
The result, as seen in Alleyne V. United States, was a judge stepping in to make a fact finding based on the lower standard that conflicted with the jury’s finding in a case based on the higher standard. The effect of the dissimilar finding was a raising of the mandatory minimum sentence imposed on the defendant and an attendant loss of power for the jury and deprivation of the defendant’s right to a jury trial.
The Court overruled Harris this week and also remanded the Alleyne case for resentencing.
As noted by Justice Breyer, the decision both restores the jury’s rightful role in sentencing proceedings and increases judges’ discretion by not forcing them to impose a higher sentence in the absence of a jury fact determination proved beyond a reasonable doubt.
Source: New York Times, “A 5-4 ruling, one of three, limits silence’s protection,” Adam Liptak, June 17, 2013