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Name: Blakely v. Washington
Case #: 02-1632
Court: US Supreme Court
District USSup
Opinion Date: 06/24/2004
Subsequent History: X-cites: 125 S.Ct. 21; 159 L.Ed.2d 851; rehrg. den. 6/24/04

Blakely pleaded guilty to kidnap. The facts admitted supported a maximum sentence of 53 months, but the judge imposed a 90-month sentence after finding that Blakely had acted with extreme cruelty, a factor for departing from the standard range. Here, the United States Supreme Court held that because the facts supporting the exceptional sentence were neither admitted by Blakely nor found by a jury, the sentence violated his Sixth Amendment right to trial by jury. The Court held that the rule of Apprendi v. New Jersey (2000) 530 U.S. 466 (that the elements of a crime – the facts that must be charged in the indictment, submitted to a jury, and proved beyond a reasonable doubt – include any fact, other than a prior conviction, which increases the maximum penalty for the crime) applies in guilty-plea cases as well as jury-trial cases. Specifically, when a defendant pleads guilty and, as part of the change-of-plea process, admits only the least-adjudicated elements of the offense, only those elements can be used to determine his sentence. If an additional fact is required to impose a higher sentence, that fact must be admitted by the defendant or tried to a jury.