## Facts

- Charles C. Apprendi, Jr. fired several shots into the home of an African-American family.
- While in custody, Apprendi made a statement (later recanted) suggesting racial motivation.
- He was charged with second-degree possession of a firearm for an unlawful purpose, carrying a 5–10 year sentencing range.
- The charging document did not invoke New Jersey’s hate-crime statute.
- Under the hate-crime statute, a judge could enhance the sentence upon finding, by a preponderance of the evidence, that the defendant acted with a purpose to intimidate based on race or other protected characteristics.
- Apprendi pled guilty to the firearm offense.
- After the plea, the prosecutor sought an enhanced sentence under the hate-crime statute.
- The sentencing judge found racial motivation by a preponderance of the evidence and imposed a 12-year sentence, exceeding the 10-year maximum for the offense of conviction.

## Issues

1. Whether the Sixth and Fourteenth Amendments require that any fact (other than a prior conviction) that increases the statutory maximum punishment be submitted to a jury and proved beyond a reasonable doubt.
2. Whether a state may permit a judge to raise the maximum sentence based on judicial fact-finding under a preponderance standard by labeling the fact a “sentencing factor.”

## Decision

- The Supreme Court reversed, holding that any fact that increases the penalty beyond the prescribed statutory maximum, other than the fact of a prior conviction, must be submitted to a jury and proved beyond a reasonable doubt.
- New Jersey’s procedure violated due process and the jury-trial guarantee by authorizing a sentence above the statutory maximum based on a judge’s bias finding under a preponderance standard.
- The Court treated the bias-motivation finding as functionally equivalent to an element because it increased the maximum punishment authorized by the conviction alone.

## Legal Principles

- The Constitution requires jury determination, beyond a reasonable doubt, of any fact (except a prior conviction) that increases the statutory maximum sentence.
- For constitutional purposes, the element/sentencing-factor label does not control; the controlling question is the effect of the fact on the permissible maximum punishment.
- Judicial discretion in sentencing is permissible only within the range authorized by the jury’s verdict (or the defendant’s valid admissions) for the offense of conviction.
- The reasonable-doubt requirement and jury trial right jointly protect against increased punishment based on facts not found by a jury.

## Conclusion

A defendant may not receive a sentence above the statutory maximum for the offense of conviction based on a judge’s finding of an aggravating fact under a preponderance standard; absent the prior-conviction exception, such a fact must be proved to a jury beyond a reasonable doubt.


Apprendi v. New Jersey, 530 U.S. 466 (2000)