Procedural History
542 U.S. 296 (2004), Supreme Court of the United States
Blakely v. Washington established that the Sixth Amendment right to a jury trial requires that any fact that increases the penalty for a crime beyond the statutory maximum must be submitted to a jury and proved beyond a reasonable doubt.
Source: 542 U.S. 296 (2004), Supreme Court of the United States
Action: Blakely was convicted of kidnapping in the second degree and, based on judicial findings, received an enhanced sentence.
Outcome: Blakely's sentence was increased beyond the standard statutory maximum due to enhancements made by the judge.
Significance: Raised questions about the constitutionality of judicial fact-finding affecting sentencing under the Sixth Amendment.
Action: Blakely appealed the enhanced sentence arguing that his Sixth Amendment rights were violated.
Outcome: The Court of Appeals upheld the enhanced sentence, agreeing with the trial court's findings and their impact on sentencing.
Significance: Continued to affirm reliance on judicial fact-finding despite the potential conflict with jury trial rights.
Action: Blakely sought further review from the Washington Supreme Court, emphasizing his right to a jury trial.
Outcome: The Washington Supreme Court affirmed the lower court's decision, leading to his petition for a writ of certiorari.
Significance: Created a path for the U.S. Supreme Court to address significant constitutional issues regarding sentencing.
Action: The U.S. Supreme Court heard Blakely's appeal on the constitutionality of his sentence.
Outcome: The Court ruled in a 5-4 decision that judicial fact-finding used to enhance sentences violated the Sixth Amendment.
Significance: Establishes a precedent requiring juries to determine any facts that lead to enhanced sentencing.
Action: The Supreme Court issued its opinion in Blakely v. Washington.
Outcome: The Court reversed the decision of the Washington Supreme Court, striking down the strictures of Washington's sentencing laws.
Significance: Significantly reshaped sentencing in the United States by reinforcing the jury's role in fact-finding for enhancements.
At the time Blakely's case reached the U.S. Supreme Court, he had exhausted avenues of appeal in Washington's state courts, which upheld the enhanced sentence based on judicially determined facts.
The standard of review applied by the Supreme Court was de novo, particularly regarding constitutional questions pertaining to the Sixth Amendment.
The Supreme Court reversed the Washington Supreme Court's decision and struck down the enhanced sentence imposed on Blakely.