Saturday, November 2, 2013

Apprendi v. New Jersey case brief

Apprendi v. New Jersey case brief summary
530 U.S. 466 (2000)

CASE SYNOPSIS
Petitioner sought a writ of certiorari to the Supreme Court of New Jersey, which affirmed petitioner's sentence under N.J. Stat. Ann. §§ 2C:43-7(a)(3), 2C:44-3(e) (2000), authorizing an extended term of imprisonment for hate crime.

CASE FACTS
Petitioner pleaded guilty to two counts of second-degree possession of a firearm for an unlawful purpose and one count of the third-degree offense of unlawful possession of an antipersonnel bomb. The state trial court enhanced the sentence under N.J. Stat. Ann. §§ 2C:43-7(a)(3), 2C:44-3(e) (2000), finding by a preponderance of the evidence that petitioner acted with a purpose to intimidate an individual or group of individuals because of race. The sentence was affirmed on appeal.

DISCUSSION
  • On writ of certiorari, the court reversed the judgment because the procedure was an unacceptable departure from the jury tradition. 
  • The Due Process Clause of U.S. Constitutional Amendment XIV required that a jury on the basis of proof beyond a reasonable doubt make the factual determination authorizing an increase in the maximum prison sentence.


CONCLUSION
The judgment of the state supreme court was reversed because it was unconstitutional to remove from the jury the assessment of facts that increased the prescribed range of penalties to which petitioner was exposed.



Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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