Blakely v. Washington
| Blakely v. Washington | |
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| Argued March 23, 2004 Decided June 24, 2004 |
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| Full case name | Ralph Howard Blakely, Jr. v. Washington |
| Citations | 542 U.S. 296 (more)
124 S. Ct. 2531; 159 L. Ed. 2d 403; 2004 U.S. LEXIS 4573; 72 U.S.L.W. 4546; 17 Fla. L. Weekly Fed. S 430
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| Prior history | Defendant sentenced, Grant County Superior Court, 11-13-00; affirmed, 47 P.3d 149 (Wash. App. 2002); review denied, 62 P.3d 889 (Wash. 2003); cert. granted, 540 U.S. 965 (2003) |
| Subsequent history | Rehearing denied, 125 S. Ct. 21 (2004) |
| Holding | |
| The State of Washington's criminal sentencing system violated the Sixth Amendment right to a jury trial, because it gave judges the ability to increase sentences based on their own determination of facts. | |
| Court membership | |
| Case opinions | |
| Majority | Scalia, joined by Stevens, Souter, Thomas, Ginsburg |
| Dissent | O'Connor, joined by Breyer; joined by Rehnquist and Kennedy except as to Part IV-B |
| Dissent | Kennedy, joined by Breyer |
| Dissent | Breyer, joined by O'Connor |
| Laws applied | |
| U.S. Const. amend. VI; Washington Sentencing Reform Act | |
Blakely v. Washington, 542 U.S. 296 (2004), held that, in the context of mandatory sentencing guidelines under state law, the Sixth Amendment right to a jury trial prohibited judges from enhancing criminal sentences based on facts other than those decided by the jury or admitted by the defendant. The landmark nature of the case (for good or ill) was alluded to by Justice Sandra Day O'Connor, who "described the Court's decision as a 'Number 10 earthquake.'"
Ralph Howard Blakely was born in 1936; he started his criminal career in 1954. Blakely married his wife in 1973. During the Blakely's 20-plus-year marriage, Mr. Blakely was involved in 80 or more lawsuits covering irrigation water rights, as well as crimes of assault, shoplifting, and many others. When his wife filed for divorce in 1996, Blakely kidnapped her from her home in rural Grant County, Washington, at knifepoint, forced her into a wooden box in the back of his pickup truck, and took her to Montana. He ordered their 13-year-old son to follow in another car, threatening to shoot his estranged wife with a shotgun if he did not comply. En route to Montana, their son escaped in Moses Lake, Washington, and alerted the police. FBI agents and sheriffs arrested Blakely in Montana near the town of Three Forks.
Blakely was charged with first-degree kidnapping, but ultimately pleaded guilty to second-degree kidnapping involving domestic violence and the use of a firearm. If one is convicted of first-degree kidnapping of a minor in Washington state, one must register as a sex offender upon release from prison. To avoid this, Mr. Blakely negotiated a plea of a longer sentence while pleading guilty only to second-degree kidnapping. At the plea hearing, Blakely admitted the facts necessary to support these charges but no others. Under Washington law, second-degree kidnapping was a class B felony, punishable by a maximum sentence of 10 years in prison. However, under Washington's mandatory sentencing guidelines, the judge was required to sentence Blakely to no less than 49 and no more than 53 months in prison, unless he had "substantial and compelling" reasons to impose a sentence outside that range. These reasons could not take into account factors used to compute the standard range for the sentence. If the judge did not articulate specific findings of fact and conclusions of law justifying an exceptional sentence, an appellate court would have to reverse the sentence.
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