Cunningham v. California, 549 U.S. 270 (2007)
Primary Holding
The California determinate sentencing law violates a defendant's right to a jury trial under the Sixth and Fourteenth Amendments by allowing a judge to impose a sentence above the statutory maximum based on facts not found by a jury or admitted by the defendant.
In the case of Cunningham v. California, the Supreme Court decided that a California law allowing judges to impose longer sentences based on facts they determine, rather than facts found by a jury, was unfair. This ruling is important because it reinforces the right to a jury trial, meaning that if someone is facing a serious penalty, a jury must decide the facts that could lead to a harsher sentence. This case is relevant for anyone involved in a criminal case where a judge's decision could affect their sentence, ensuring that their rights are protected and that they have a fair trial.
AI-generated plain-language summary to help you understand this case
In Cunningham v. California, John Cunningham was convicted of continuous sexual abuse of a child under the age of 14. Under California's determinate sentencing law (DSL), this offense carried a range of possible sentences: a lower term of 6 years, a middle term of 12 years, or an upper term of 16 years. The trial judge, following a post-trial sentencing hearing, found six aggravating circumstances by a preponderance of the evidence, including the victim's particular vulnerability and Cunningham's violent conduct. The judge also noted one mitigating factor: Cunningham had no prior criminal record. Ultimately, the judge sentenced Cunningham to the upper term of 16 years, reasoning that the aggravating factors outweighed the mitigating factor. The case progressed through the California court system, where a panel of the California Court of Appeal affirmed Cunningham's conviction and sentence. One judge dissented, arguing that the increase in Cunningham's sentence based on judicial factfinding was inconsistent with the precedent established by the U.S. Supreme Court. The California Supreme Court subsequently denied review of the case, which led to Cunningham petitioning for a writ of certiorari to the U.S. Supreme Court. The relevant background context involves the constitutional implications of California's DSL, particularly regarding the Sixth and Fourteenth Amendments, which guarantee the right to a jury trial. The Supreme Court's opinion focused on whether the DSL's provision allowing judges to determine facts that could elevate a defendant's sentence violated this right. The Court ultimately held that the DSL's framework, which permitted a judge to impose a sentence above the statutory maximum based on facts not found by a jury or admitted by the defendant, was unconstitutional.
Whether California’s determinate sentencing law, which allows a judge to find facts that elevate a defendant's sentence beyond the statutory maximum without a jury's determination, violates the defendant's right to a trial by jury as safeguarded by the Sixth and Fourteenth Amendments.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- October 11, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Ginsburg
- Damages Awarded
- N/A
- Data Quality
- high
Ayers v. Belmontes, 549 U.S. 7 (2006)
Consumer LostA capital defendant's right to present mitigating evidence during sentencing is not violated when the jury is instructed to consider specific aggravating and mitigating factors, as long as the jury is not precluded from considering relevant evidence that may influence their decision.
Washington v. Recuenco, 548 U.S. 212 (2006)
Consumer LostA violation of the Sixth Amendment right to a jury trial, as established in Blakely v. Washington, is not subject to a harmless error analysis; thus, any such violation requires the vacating of the sentence.
United States v. Booker, 543 U.S. 220 (2005)
Consumer LostThe Federal Sentencing Guidelines are unconstitutional as applied in a manner that requires judges to find facts by a preponderance of the evidence that increase a defendant's sentence beyond the statutory maximum, violating the Sixth Amendment right to a jury trial.
Rice v. Collins, 546 U.S. 333 (2006)
Consumer LostA federal court must defer to reasonable state-court determinations of fact in a habeas corpus case and cannot set aside those determinations based on its own interpretations of the record.