Supreme Court Holds that Juries Must Decide Facts Which Increase Mandatory Minimum Punishments

The U.S. Supreme Court handed down a decision last week in Alleyne v. United States, which ruled that juries must decide any facts which could increase the minimum mandatory sentence for a defendant. Previously, judges would often decide such facts without any finding of fact from the jury. The case before the Supreme Court involved Allen Alleyne who was convicted of robbery and use of a firearm during the commission of a crime. During trial, the prosecution asserted that one of Alleyne's accomplices "brandished" a firearm during the commission of the robbery. However, on the jury's verdict form it found that a firearm was "used" and/or "carried" during the commission of the crime, not "brandished." For sentencing purposes, the judge presiding over the trial determined that a weapon was "brandished" despite the jury's silence on the matter. Due to the judge's decision, Alleyne received an increased mandatory minimum punishment of seven years. The subtle difference between "carrying" or "brandishing" a weapon during the commission of a crime can change the mandatory minimum sentence from five years to seven years. Alleyne objected to this increase in punishment at sentencing, and he argued that such an increase, without a finding of fact by the jury that he brandished the weapon, violated his Sixth Amendment rights. The Supreme Court agreed with Alleyne by stating "[b]ecause mandatory minimum sentences increase the penalty for a crime, any fact that increases the mandatory minimum is an 'element' that must be submitted to the jury." This ruling means that any fact that can increase punishment for a crime will now have to be proven "beyond a reasonable doubt" to the jury before the increased sentencing can be applied. Accordingly, in Alleyne's matter, the trial court's decision was reversed and remanded for sentencing based on its ruling.