## Facts

- Allen Ryan Alleyne participated in a convenience-store robbery in Petersburg, Virginia, during which a firearm was used.
- He was charged under 18 U.S.C. § 924(c)(1)(A) for using or carrying a firearm during and in relation to a crime of violence, which sets escalating mandatory minimums based on specified firearm-related facts.
- The jury found Alleyne guilty of robbery and found only that he “used or carried a firearm” during a crime of violence; the jury made no finding that the firearm was “brandished.”
- At sentencing, the district judge found by a preponderance of the evidence that the firearm was brandished and imposed the 7-year mandatory minimum under § 924(c)(1)(A)(ii), rather than the 5-year minimum under § 924(c)(1)(A)(i).
- The court of appeals affirmed, relying on precedent permitting judicial fact-finding that increases a mandatory minimum.

## Issues

1. Whether the Sixth Amendment requires any fact that increases a mandatory minimum sentence to be treated as an element of the offense.
2. Whether such a fact must be submitted to a jury and proved beyond a reasonable doubt rather than found by a judge at sentencing.
3. Whether precedent allowing judges to find facts that raise mandatory minimums should be retained.

## Decision

- The Supreme Court vacated and remanded.
- The Court held that any fact increasing a mandatory minimum sentence increases the legally prescribed punishment and therefore must be submitted to the jury and found beyond a reasonable doubt.
- The Court overruled Harris v. United States, which had allowed judicial fact-finding to raise mandatory minimums.
- Because “brandishing” raised the minimum sentence under § 924(c)(1)(A) from five to seven years, it was an element of an aggravated offense that the jury had to find.

## Legal Principles

- A fact that increases a mandatory minimum sentence is an element of the offense for Sixth Amendment purposes.
- Elements that alter the legally authorized sentencing range must be charged and proved to a jury beyond a reasonable doubt.
- Judges may still find facts that guide sentencing discretion within the range authorized by the jury’s verdict; the constitutional violation arises when judicial fact-finding changes the statutory sentencing range itself (including its floor).
- The rule extending Apprendi to mandatory minimums eliminates the prior distinction between facts raising maximum penalties and facts raising minimum penalties.

## Conclusion

The Court held that increasing a mandatory minimum based on judge-found facts violates the Sixth Amendment because such facts function as offense elements; “brandishing” could not raise Alleyne’s minimum sentence unless the jury found it beyond a reasonable doubt, and prior contrary precedent was overruled.


Alleyne v. United States, 570 U.S. 99 (2013)