Apprendi v. New Jersey
| Apprendi v. New Jersey | |
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| Argued March 28, 2000 Decided June 26, 2000 |
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| Full case name | Charles C. Apprendi, Jr. v. New Jersey |
| Citations | 530 U.S. 466 (more)
120 S. Ct. 2348; 147 L. Ed. 2d 435; 2000 U.S. LEXIS 4304; 68 U.S.L.W. 4576; 2000 Cal. Daily Op. Service 5061; 2000 Daily Journal DAR 6749; 2000 Colo. J. C.A.R. 3722; 13 Fla. L. Weekly Fed. S 457
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| Prior history | Defendant sentenced after plea agreement, Superior Ct. of New Jersey, Law Div., Cumberland Cty., 1995; affirmed, 698 A.2d 1265 (N.J. Super. Ct. App. Div. 1997); affirmed, 731 A.2d 485 (N.J. 1999); cert. granted, 528 U.S. 1018 (1998) |
| Holding | |
| Other than the fact of a prior conviction, every fact necessary to authorize a defendant's punishment must be either admitted by the defendant or found by a jury on proof beyond a reasonable doubt. The New Jersey Hate Crime Statute was an unconstitutional violation of the Sixth Amendment right to a jury trial because it allowed a judge to increase a criminal sentence beyond its statutory maximum based on his own finding of an aggravating factor by the preponderance of the evidence. New Jersey Supreme Court reversed and remanded. | |
| Court membership | |
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| Case opinions | |
| Majority | Stevens, joined by Scalia, Souter, Thomas, Ginsburg |
| Concurrence | Scalia |
| Concurrence | Thomas, joined by Scalia (parts I, II) |
| Dissent | O'Connor, joined by Rehnquist, Kennedy, Breyer |
| Dissent | Breyer, joined by Rehnquist |
| Laws applied | |
| U.S. Const. amend. VI; N.J. Stat. Ann. § 2C:44-3(e) (New Jersey Hate Crime Statute) | |
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, which struck down Arizona's judge-only method of imposing the death penalty, and also in Blakely v. Washington, which ruled that mandatory state sentencing guidelines are the statutory maximum for purposes of applying the Apprendi rule.
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.
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