Sentencing
Rulings about jury findings at sentencing, sentence enhancements, capital sentencing, and juvenile sentencing. Summaries from Criminal Defense Resources™ are general education for pro per/pro se defendants and families, not legal advice.
5 rulings, newest first.
Erlinger v. United States
The Court held that, under the federal Armed Career Criminal Act, whether a defendant's past offenses happened on separate "occasions" must be decided by a unanimous jury beyond a reasonable doubt (or admitted by the defendant), not decided by a judge.
State v. Soto-Fong
The Arizona Supreme Court held that consecutive prison sentences for multiple crimes committed as a juvenile do not violate the Eighth Amendment, even when the total exceeds the person's life expectancy, because the U.S. Supreme Court's juvenile-sentencing cases address sentences for single crimes.
Lynch v. Arizona
In a short unsigned opinion, the Court held that when a capital defendant's future dangerousness is at issue and the only alternative to death is life without parole, the defendant is entitled to tell the jury he would not be eligible for parole. The possibility of future clemency or law changes does not remove that right.
Ring v. Arizona
The Court held that Arizona's death-penalty system, which let a judge alone find the aggravating factors needed for a death sentence, violated the right to a jury trial. A jury must find those factors.
Apprendi v. New Jersey
The Court held that, other than a prior conviction, any fact that raises the penalty for a crime beyond the maximum set by law must be decided by a jury and proved beyond a reasonable doubt.
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