- Source: Erlinger v. United States
Erlinger v. United States, 602 U.S. 821 (2024), was a United States Supreme Court case relating to the right to a jury trial in criminal cases under the Fifth and Sixth Amendments. The case was argued on January 16, 2024, and decided on June 21.
Background
Paul Erlinger was charged and convicted of being a felon in possession of a firearm in 2018. He was sentenced to 15 years and sought post-conviction relief. The District Court found that Erlinger had committed three separate burglaries, making him eligible for the ACCA enhancement. Erlinger objected, arguing that the burglary question should have been found by a jury. The Supreme Court held in Apprendi v. New Jersey that:
"[o]ther than the fact of a prior conviction, any fact that increases the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury, and proved beyond a reasonable doubt."
The United States District Court for the Southern District of Indiana overruled his objection and re-imposed the 15-year sentence. Erlinger appealed to the United States Court of Appeals for the Seventh Circuit, which affirmed his sentence, holding that the government was only required to prove the burglary question to the judge by a preponderance of the evidence, as opposed to beyond a reasonable doubt. The Supreme Court granted certiorari on November 20, 2023.
See also
Apprendi v. New Jersey
Blakely v. Washington
United States v. Booker
References
External links
Text of Erlinger v. United States, 602 U.S. ___ (2024) is available from: Cornell Justia Oyez (oral argument audio) Supreme Court (slip opinion)