Washington

Blakely v. Washington in Washington Law

How Blakely v. Washington applies in Washington: state-specific rules, key cases, and bar exam notes for Criminal Procedure.

State Approach

In Washington, the principles established in Blakely v. Washington emphasize that any fact that increases a sentence beyond the standard range must be proven to a jury beyond a reasonable doubt. This reinforces the right to a jury trial in determining facts that influence sentencing.

State Rule
Under Washington law, any aggravating factor that leads to an exceptional sentence must be found by a jury and proven beyond a reasonable doubt, consistent with the Sixth Amendment ruling in Blakely.
Significant State Cases

State v. King

The court ruled that the sentencing enhancements based on facts not found by a jury violate the rights established in Blakely.

State v. Hughes

The ruling reinforced that any fact increasing the maximum sentence must be presented to a jury, following the precedent set by Blakely.

State v. Caldwell

Determined that failure to have a jury decide on enhancements results in an unconstitutional sentence under Blakely.

Comparison to Federal Law

Washington’s interpretation of Blakely closely aligns with federal standards, emphasizing jury findings in sentencing enhancements. However, Washington has also developed specific statutory frameworks for addressing how enhancements are applied, which may differ from federal practices.

Bar Exam Note

Understanding Blakely is crucial for Washington bar exam takers, particularly in Criminal Procedure, as it addresses foundational rights regarding sentencing and jury determinations.

Practice Pointers
  • Ensure that any sentencing enhancements are supported by jury findings to comply with Blakely.
  • Familiarize yourself with how statutory aggravating factors are defined in Washington law.
  • Review case law applying Blakely principles to understand how courts interpret jury roles in sentencing.

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