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Supreme Court: with mandatory minimums, jury must decide facts

A key United States Supreme Court ruling issued earlier this week has been long anticipated by legal scholars across the country, including in Missouri, who have pointed to a disconnect in some sentencing matters relating to federal criminal charges.

That disconnect owed to Harris v. United States, a case decided by the Court in 2002 on the heels of an earlier case called Apprendi v. New Jersey. The former case enunciated an important constitutional principle, namely, that the jury -- not a judge -- must make a finding on any fact that has the potential to increase a defendant’s sentence beyond a statutory maximum (e.g., a felony murder using a firearm; especially high-volume drug trafficking), finding that the fact must be proved “beyond a reasonable doubt” in order for a sentence to be enhanced.

In the view of many legal commentators, the Harris case undercut that ruling significantly by providing that a jury not be compelled to weigh in and make a fact finding in a case where doing so would trigger a mandatory minimum -- not maximum, as in Apprendi -- sentence.

The Court’s rational in Harris was that the high standard of “beyond a reasonable doubt” need only apply in cases where there is a potential for a sentence to be imposed that is longer than what is provided for by statute. In instances of mandatory minimum triggering, the Court ruled that a judge must step in when perceiving jury error and make a finding based on the lower threshold for determining guilt provided by the “preponderance of the evidence” standard.

In a case decided this past Monday, the Court overruled Harris and strongly affirmed Apprendi. The Court stated that a fatal inconsistency existed when two different standards applied to fact finding, and that a defendant’s constitutional right to a jury trial under the Sixth Amendment is denied in any case where the jury does not find all facts related to the range of penalties for a charged crime.

What this most centrally means going forward is that, in cases where federal statutes prescribe a range of mandatory minimum sentence possibilities, a jury must make a fact finding as a prerequisite to a judge handing down a sentence.

Source: SCOTUSbog, "Reconciling ceilings and floors: "Alleyne v. United States," Mike Gottlieb, June 17, 2013

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