Apprendi v. New Jersey Case Brief

Why is the case important?

Racially-motivated crime brought a sentence well above what he could have received.

Facts of the case

Charles C. Apprendi, Jr. fired several shots into the home of an African- American family. While in custody, Apprendi made a statement, which he later retracted, that he did not want the family in his neighborhood because of their race. Apprendi was charged under New Jersey law with second-degree possession of a firearm for an unlawful purpose, which carries a prison term of 5 to 10 years. The count did not refer to the state’s hate crime statute, which provides for an enhanced sentence if a trial judge finds, by a preponderance of the evidence, that the defendant committed the crime with a purpose to intimidate a person or group because of race. After Apprendi pleaded guilty, the prosecutor filed a motion to enhance the sentence. The court found, by a preponderance of the evidence, that the shooting was racially motivated and sentenced Apprendi to a 12-year term on the firearms count. In upholding the sentence, the appeals court rejected Apprendi’s claim that the Due Process Clause requires that a bias finding be proved to a jury beyond a reasonable doubt. The State Supreme Court affirmed.

Question

Whether the Due Process Clause of the Fourteenth Amendment requires that a factual determination authorizing an increase in the maximum prison sentence for an offense from 10 to 20 years be made by a jury on the basis of proof beyond a reasonable doubt.

Answer

Yes. The Supreme Court recognized that at stake in this case are constitutional protections of surpassing importance: the proscription of any deprivation of liberty without ‘due process of law,’ and the guarantee that in all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury. The Court further discussed the historic link between verdict and penalty and the inherent predictability the defendant was protected with. The Court required the application of the reasonable doubt standard to sentencing so as to limit error.

Conclusion

The court reversed the judgment because the procedure was an unacceptable departure from the jury tradition. The Due Process Clause of U.S. Const. amend. XIV required that a jury on the basis of proof beyond a reasonable doubt make the factual determination authorizing an increase in the maximum prison sentence.

  • Case Brief: 2000
  • Petitioner: Apprendi
  • Respondent: New Jersey
  • Decided by: Rehnquist Court

Citation: 530 US 466 (2000)
Argued: Mar 28, 2000
Decided: Jun 26, 2000