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Name: Wilson v. Knowles
Case #: 07-17318
Court: US Court of Appeals
District 9 Cir
Opinion Date: 04/01/2011

A defendant is entitled to a jury trial on disputed facts resulting in an increase in sentence. In 1993, Wilson was convicted by plea of vehicular manslaughter and proximately causing bodily injury resulting from a driving-under-the-influence incident. In the instant case, he was convicted of felony driving under the influence. The judge found the 1993 convictions to be a first and second strike and sentenced appellant to 25 years to life. Finding the state court’s decision was contrary to or involved an unreasonable application of clearly established Supreme Court precedent, the appellate court reversed and remanded. Apprendi v. New Jersey (2000) 530 U.S. 466 held that, except for the fact of a prior conviction, facts that increase a defendant’s sentence beyond the statutory maximum must be proved to a jury beyond a reasonable doubt. The trial court’s finding that the 1993 incident constituted “strikes” because of personal infliction of great bodily injury did not fall within the prior conviction exception to defendant’s right to a jury trial. The error is not harmless because no court could look at disputed facts of a seven year old incident and conclude beyond a reasonable doubt that Wilson would have been convicted of personally inflicting great bodily injury. Accordingly, Wilson is entitled to a jury trial as to whether he has the requisite “strikes” allowing for imposition of the life sentence.