Apprendi v. New Jersey, 530 U.S. 466 (2000), is a landmark United States Supreme Court decision with regard to aggravating factors in crimes.

The Apprendi decision was subsequently cited as precedent by the court in its consideration of Ring v. Arizona (2002), which struck down Arizona's judge-only method of imposing the death penalty, and also in Blakely v. Washington (2004), which ruled that mandatory state sentencing guidelines are the statutory maximum for purposes of applying the Apprendi rule.

In the early morning hours of December 22, 1994, Charles Apprendi Jr., fired several .22-caliber bullets into the home of an African-American family that had recently moved into his neighborhood.

As part of the plea bargain, the prosecution reserved the right to seek an enhanced sentence on the basis that the crime was committed with a biased purpose.

Apprendi, in turn, reserved the right to challenge the bias crime enhancement, claiming it violated the federal Constitution.

At a later hearing, he heard testimony from Apprendi himself as well as from psychologists stating that the shooting was not motivated by racial hatred but instead was the result of intoxication.

The Appellate Division of the New Jersey Superior Court affirmed the enhancement on the grounds that it was a "sentencing factor" rather than an "element" of the crime, and therefore not subject to the jury-trial and proof-beyond-a-reasonable-doubt requirements of the Constitution.

In this case, the hate-crime enhancement was determined by a judge, sitting alone, and subjected to a lower standard of proof — a preponderance of the evidence, instead of beyond a reasonable doubt.

Under the Constitution, due process gives criminal defendants two interdependent procedural safeguards with respect to the manner in which the sentence is determined.

The first of these is the jury trial, a "guard against a spirit of oppression and tyranny on the part of the rulers" and "the great bulwark of our civil and political liberties," whereby "the truth of every accusation, whether preferred in the shape of indictment, information, or appeal, should afterwards be confirmed by the unanimous suffrage of twelve of the defendant's equals and neighbors."

This was not to say that "trial practices cannot change in the course of centuries and still remain true to the principles that emerged from the Framers' fears that the jury right could be lost not only by gross denial, but by erosion."

With the decision in In re Winship in 1970, the Court expressly said for the first time that due process demands from the government proof beyond a reasonable doubt of every element of a crime.

Two years before Apprendi, the Court decided Almendarez-Torres v. United States, 523 U.S. 224 (1998), in which the Court held that a federal statute authorizing increased punishment for illegally reentering the United States after deportation pursuant to a conviction for certain crimes was constitutional despite a then-emerging view (later solidified in Apprendi) that facts that increased punishment must be proved to a jury beyond a reasonable doubt.

Although the Court in Mullaney v. Wilbur, 421 U.S. 684 (1975), may have ruled that the jury-trial and reasonable-doubt requirements applied to the facts that dictated the degree of homicide crime the defendant had committed, and thus the level of punishment to which he was subject, two years later, in Patterson v. New York, 432 U.S. 197 (1977), the Court ruled that a state could place on defendants the burden of proving affirmative defenses, such as extreme emotional disturbance.

Patterson, for Justice O'Connor, repudiated the general principle that facts bearing on the degree of punishment must be proved to a jury beyond a reasonable doubt.

In Southern Union Co. v. United States (2012), the Supreme Court determined that when a criminal fine is sufficient to trigger the Sixth Amendment jury-trial guarantee, facts that would increase the penalty beyond the statutory maximum must be submitted to a jury and proved beyond a reasonable doubt.

Respondent was convicted of storing hazardous liquid mercury without a permit, "on or about September 19, 2002 to October 19, 2004," in violation of the Resource Conservation and Recovery Act (42 U.S.C.

The Court of Appeals for the First Circuit upheld the sentence, agreeing that the jury had not determined the duration of the violation, but holding that Apprendi did not apply to criminal fines.