Appellant was convicted of multiple felonies, and was found sane at the time he committed the crimes. On appeal, he claimed that Apprendi impliedly altered the burden of proof on the question of insanity, now requiring the prosecution to prove sanity beyond a reasonable doubt. The appellate court rejected the argument. Sanity is not an element of the offense charged; the question is one of insanity as a defense. A finding of sanity does not increase the maximum penalty one can receive. Neither Apprendi nor Ring in any way impliedly overrules decisions holding that insanity is not an element of a criminal offense.