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Alleyne v. United States

United States Supreme Court

570 U.S. ___ (2013)

Relevant factsFree

Alleyne (defendant) was convicted of a firearm offense carrying escalating mandatory minimums depending on how the gun was used — five years for carrying, seven for brandishing, ten for discharging — but the jury never specified which level applied; the sentencing judge found Alleyne's accomplice had brandished the gun and imposed the seven-year minimum, and the Fourth Circuit affirmed under the existing precedent Harris v. United States, which had allowed judges to find mandatory-minimum-triggering facts without a jury.

IssueFree

Whether a fact that increases a crime's mandatory minimum sentence is an element of the crime that must be submitted to the jury and proven beyond a reasonable doubt.

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