Blakely v. Washington
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| Blakely v. Washington | ||||||||
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| Image:Seal of the United States Supreme Court.png Supreme Court of the United States | ||||||||
| Argued March 23, 2004 Decided June 24, 2004 | ||||||||
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| Holding | ||||||||
| The State of Washington's criminal sentencing system violated the Sixth Amendment right to a jury trialTemplate:Fn, because it gave judges the ability to increase sentences based on their own determination of facts. Judgment of Washington Court of Appeals reversed and case remanded. | ||||||||
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| Case opinions | ||||||||
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| Laws applied | ||||||||
| U.S. Const. Amend. VI;Template:Fn Washington Sentencing Reform Act |
Blakely v. Washington, 542 U.S. 296 (2004), was a United States Supreme Court decision. The Court ruled, five to four, that the Sixth Amendment right to a jury trialTemplate:Fn prohibited judges from enhancing criminal sentences based on facts other than those decided by the jury or confessed to by the defendant.
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Background of the case
The case involved the sentencing of Ralph Blakely, Jr., a man who had pled guilty to kidnapping his estranged wife in Grant County, Washington. The Washington state Sentencing Reform Act required standard sentences according to statutory guidelines unless the judge found "aggravating circumstances." In Blakely's case, the judge found, independently of what Blakely had confessed to, that he had acted with "deliberate cruelty." The judge raised Blakely's standard sentence of 53 months up to 90.
Blakely appealed his sentence in state court as a violation of his Sixth Amendment right to a jury trial.Template:Fn The Washington Court of Appeals affirmed the trial judge's determination and the Washington Supreme Court denied discretionary review.
The Court's decision
Blakely was then granted review by the U.S. Supreme Court, which reversed the Washington Court of Appeals and remanded Blakely's sentence for a redetermination and reduction by the Washington courts. The Court's ruling also had the effect of invalidating sentencing schemes such as the Washington Sentencing Reform Act, that give judges the power to increase sentences based on facts not confessed to nor found by a jury.
The Court's opinion extended beyond Apprendi v. New Jersey, 530 U.S. 466 (2000), in which a New Jersey hate crime law was struck because it allowed judges to enhance sentences beyond the statutory maximum based on their own finding of aggravating circumstances, in contrast to the Washington system invalidated here. The Justices voted along the same divisions in Apprendi as in Blakely.
Notes
*Template:Fnb As applied to the states through the Fourteenth Amendment; see Incorporation.
External links