Blakely v. Washington
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| Blakely v. Washington | ||||||||
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 Supreme Court of the United States | ||||||||
| Argued March 23, 2004 Decided June 24, 2004 | ||||||||
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| 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. Judgment of Washington Court of Appeals reversed and case remanded. | ||||||||
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| Laws applied | ||||||||
| U.S. Const. Amend. VI; Washington Sentencing Reform Act |
Blakely v. Washington 124 S.Ct. 2531 (2004) was a United States Supreme Court decision. The Court ruled, 5-4, that 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 confessed to by the defendant.
Case background
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. The Washington Court of Appeals affirmed the trial judge's determination and the Washington Supreme Court denied discretionary review. 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 the scope of the Apprendi decision, in requiring jury determination of aggravating circumstances that increased a sentence, even when the sentence was within the statutory limits for the unaggravated offense.
External Links
Text of opinion from Findlaw.com (http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=us&vol=000&invol=02-1632)
Court denies rehearing in Blakely case (http://www.typepad.com/t/trackback/1047270)