## Facts

- Ralph Howard Blakely, Jr. pleaded guilty in Washington state court to second-degree kidnapping involving domestic violence and use of a firearm, arising from abducting his estranged wife at knifepoint and transporting her from Washington to Montana.
- Under Washington’s Sentencing Reform Act, Blakely’s plea and offender score produced a standard sentencing range of 49–53 months.
- The facts admitted in the plea, standing alone, authorized a maximum sentence of 53 months within that range.
- The trial judge imposed an exceptional sentence of 90 months after finding, by a preponderance of the evidence, that Blakely acted with “deliberate cruelty,” a statutory aggravating factor allowing departure above the standard range.
- The Washington Court of Appeals affirmed, and the Washington Supreme Court denied review.
- The U.S. Supreme Court granted certiorari.

## Issues

1. Whether the Sixth Amendment jury-trial right is violated when a judge finds facts (other than a prior conviction) necessary to impose a sentence above the maximum authorized by the plea or verdict.
2. Whether such penalty-increasing facts must be proved to a jury beyond a reasonable doubt rather than found by a judge under a preponderance standard.
3. How to define the “statutory maximum” for Sixth Amendment purposes in a guideline-based sentencing scheme.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that the 90-month exceptional sentence violated the Sixth Amendment because the aggravating facts supporting it were neither admitted by Blakely nor found by a jury.
- The Court reaffirmed Apprendi’s rule that, except for prior convictions, any fact increasing punishment beyond the relevant maximum must be submitted to a jury and proved beyond a reasonable doubt.
- The Court defined the relevant “statutory maximum” as the greatest sentence a judge may impose based solely on the facts reflected in the jury verdict or admitted by the defendant.
- Applying that definition, the relevant maximum was 53 months; the judge’s finding of “deliberate cruelty” could not constitutionally authorize the 90-month sentence.

## Legal Principles

- For Sixth Amendment purposes, the “statutory maximum” is the maximum sentence authorized by the verdict or the defendant’s admissions alone, not the highest sentence listed in the criminal statute.
- Any fact (other than a prior conviction) that raises the legally authorized sentencing ceiling must be treated as an element: it must be found by a jury beyond a reasonable doubt or admitted by the defendant.
- Legislative labels such as “sentencing factor” do not control; the constitutional question is whether additional fact-finding is required to increase the legally permissible sentence.
- Judicial fact-finding is permissible at sentencing only within the range authorized by the verdict or admissions; it cannot expand the authorized maximum.
- Mandatory guideline schemes that condition higher sentencing ranges on additional factual findings implicate the jury-trial right unless those facts are jury-found or admitted.

## Conclusion

The Court held that Washington’s exceptional-sentence procedure violated the Sixth Amendment because it permitted a judge to increase the maximum sentence authorized by the plea based on judicially found aggravating facts, rather than jury findings beyond a reasonable doubt (or the defendant’s admissions).


Blakely v. Washington, 542 U.S. 296 (2004)