Alleyne v. United States
133 S. Ct. 2151
| SCOTUS | 2013Background
- Alleyne and an accomplice planned to rob a store deposits while the manager drove to the bank.
- They used a ruse to stop the manager; an accomplice brandished a gun and demanded deposits.
- Alleyne was charged with § 1951(a) and § 924(c)(1)(A); the verdict form showed firearm use but not brandishing.
- The presentence report favored a 7-year minimum under § 924(c)(1)(A)(ii); Alleyne objected that brandishing wasn’t proven beyond a reasonable doubt.
- District Court held brandishing could be found by preponderance of the evidence under Harris; Alleyne was sentenced to 7 years on § 924(c).
- Court of Appeals affirmed, citing Harris as controlling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether brandishing a firearm to trigger a higher minimum is an element | Alleyne: jury must find brandishing beyond a reasonable doubt | Alleyne: Harris should control, judge may find by preponderance | Yes; brandishing is an element and must be found by jury beyond reasonable doubt |
| Whether Harris should be overruled to apply Apprendi to mandatory minimums | Alleyne: Harris conflicts with Apprendi and should be overruled | Harris controls minimums; no overrule | Overruled; Harris overruled and Apprendi applies to mandatory minimums |
Key Cases Cited
- Apprendi v. New Jersey, 530 U.S. 466 (2000) (any fact increasing the penalty beyond the prescribed maximum must be found by jury)
- Harris v. United States, 536 U.S. 545 (2002) (limited Apprendi to maximums; permitted judge to impose minimums based on non-jury findings)
- McMillan v. Pennsylvania, 477 U.S. 79 (1986) (elements vs. sentencing factors; precursor to Apprendi)
- Ring v. Arizona, 536 U.S. 584 (2002) (Apprendi-based Sixth Amendment questioning of capital-sentencing process)
- Blakely v. Washington, 542 U.S. 296 (2004) (clarified Apprendi’s jury-trial requirement in state contexts)
- United States v. Gaudin, 515 U.S. 506 (1995) (jury right and factual determinations for sentencing)
- United States v. Booker, 543 U.S. 220 (2005) (guidelines restructured but Sixth Amendment implications carry forward)