Cunningham v. California (2006)
- Docket
- 05-6551
- Decided
- 2006-01-01
Summary
Question: Does California's Determinate Sentencing Law violate the 6th Amendment right to a jury trial by permitting judges to impose enhanced sentences based on their determination of facts not found by the jury or admitted by the defendant? Conclusion: Yes. The Court ruled 6-3 that California's Determinate Sentencing Law was inconsistent with the Sixth Amendment right to trial by jury. The opinion by Justice Ruth Bader Ginsburg held that "[...] under the Sixth Amendment, any fact that exposes a defendant to a greater potential sentence must be found by a jury, not a judge, and established beyond a reasonable doubt, not merely by a preponderance of the evidence." Because the maximum sentence could not be given unless aggravating circumstances were found, and because the aggravating circumstances "depend[ed] on facts found discretely and solely by the judge," the Court found that California's sentencing system circumvented the process of trial by jury. In his dissent, Justice Alito argued that the California system was similar to the advisory federal sentencing guidelines which were upheld in United States v. Booker .