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Name: U.S. v. Tighe
Case #: 00-30263
Court: US Court of Appeals
District 9 Cir
Opinion Date: 09/24/2001
Subsequent History: None

The district court violated Apprendi v. New Jersey (2000) 530 U.S. 466, when it counted as a predicate offense for purposes of the Armed Career Criminal Act a prior juvenile adjudication. Apprendi requires that other than the fact of a prior conviction, any fact that increases the penalty for a crime beyond the statutory maximum must be submitted to a jury and proved. The “prior conviction” exception to Apprendi’s general rule must be limited to prior convictions that were obtained through proceedings that included the right to a jury trial. Therefore, the prior convictions exception does not apply to prior juvenile adjudications, and the trial court erred when it increased Tighe’s penalty beyond the prescribed statutory maximum based on that adjudication.