Alleyne v. United States

Background

A man and an accomplice pretended their car had trouble to stop a store manager and then robbed him at gunpoint. The defendant was convicted of robbery affecting interstate commerce and of using or carrying a firearm in relation to a crime of violence. The jury found he had used or carried a gun but did not find that the gun was brandished. At sentencing the judge found brandishing and imposed a seven-year mandatory minimum on the firearm count, which the defendant challenged as violating his right to have a jury decide facts that increase punishment.

Reasoning

The Court addressed whether a fact that, by law, raises the mandatory minimum sentence must be treated as an element of the crime and proved to a jury beyond a reasonable doubt. Relying on prior decisions about facts that increase statutory punishment, the Court concluded that any fact that increases either the floor or the ceiling of the statutory range becomes part of the offense. Because brandishing raised the mandatory minimum, the judge’s finding should have been decided by the jury. The Court overruled earlier precedents that had allowed judges to make such findings by a lower standard.

Real world impact

The ruling means defendants cannot have their mandatory minimum prison terms raised based on judge-found facts alone; juries must decide those aggravating facts. Prosecutors and courts will need to treat facts that trigger higher minimums as issues to charge and prove to juries. The Court vacated the sentencing enhancement in this case and sent the case back for resentencing consistent with the jury’s verdict.

Dissents or concurrances

Several Justices joined the judgment but wrote separately; Justice Breyer concurred in part. Chief Justice Roberts, joined by Justices Scalia and Kennedy, dissented, arguing the decision misreads history, undermines judicial sentencing discretion, and weakens stare decisis; Justice Alito also wrote a dissent expressing similar concerns.