Alleyne v. United States

Alleyne v. United States

Argued January 14, 2013
Decided June 17, 2013
Full case name Allen Ryan Alleyne, Petitioner v. United States
Docket nos. 11-9935
Holding
Because mandatory minimum sentences increase the penalty for a crime, any fact that increases the mandatory minimum is an “element” of the crime that must be submitted to the jury.
Court membership
Case opinions
Majority Thomas (Parts I, III-B, III-C, IV), joined by Ginsburg, Kagan, Sotomayor (in full); Breyer (except as to parts II and III-A)
Concurrence Sotomayor, joined by Ginsburg, Kagan
Concurrence Breyer (in part and in judgement)
Dissent Roberts, joined by Scalia, Kennedy
Dissent Alito
Laws applied
Amendment VI
This case overturned a previous ruling
Harris v. United States

Alleyne v. United States (2013) is a Supreme Court case that decided that, in line with Apprendi v. New Jersey (2000), all facts that increase a mandatory minimum sentence must be submitted to and found true by a jury (not merely determined to be true by a judge's discretion). The majority opinion was written by Justice Clarence Thomas, joined by Justices Ginsburg, Breyer, Sotomayor, and Kagan.

Summary of findings

In the original trial, the defendant (Alleyne) was convicted of using or carrying a firearm in a violent crime, which carried a mandatory minimum penalty of five years' imprisonment. However, the mandatory minimum would rise to seven years if the accused were found to have "brandished" the firearm during the crime, and to ten years if he had fired it. In the original trial, the judge (not the jury) determined that Alleyne had probably brandished the firearm during the robbery, which caused the mandatory minimum sentence to rise to seven years (which was the sentence imposed).

The Supreme Court found that the question of whether or not the accused had brandished his weapon during the robbery was not merely a "sentencing factor," which the judge could unilaterally decide, but an "ingredient of the offense," which must be assessed and decided upon by the jury. The Court also expressly overruled Harris v. United States (2002), which had reached a contrary ruling.[1]

See also

References

  1. ↑ "SUPREME COURT UPDATE: ALLEYNE V. UNITED STATES (11-9335) AND SALINAS V. TEXAS (12-246)". Appellate and Complex Legal Issues Practice Group, Wiggin and Dana LLP. June 19, 2013. Retrieved July 27, 2013.

External links