Judicially Determined Mandatory Minimum Sentences for Drug Offenses No Longer Legal in PA

Supreme Court Rulings Impact Minimum Sentencing Laws

In 2000, the Supreme Court ruled in Apprendi v. New Jersey held that facts in a case which may augment a criminal defendant’s sentence, up to the maximum sentence allowed, are to be considered “elements” of the offenses in question. As such, these elements are required to be proven to a jury beyond a reasonable doubt.

For example, consider a felony criminal case involving the distribution of a controlled substance. If there is a ten year minimum sentence mandated by state statutes, with additional time to be added to the sentence dependant on the quantity of the drug, then it must be the jury and not the judge to declare a finding on the quantity in question prior to the increased maximum sentence being imposed.

Juries Must Establish Whether A Mandatory Minimum Should Apply

In 2013, the Supreme Court again ruled on the topic of mandatory minimum sentences. The High Court held that juries and not judges must determine whether or not minimum mandatory sentencing guidelines should apply in the case at hand. Due to the legal precedence established by this decision, some Pennsylvania counties such as such as Lycoming, Allegheny and Blair ceased imposing mandatory minimum sentences.

Evidence Relevant To Mandatory Minimums Must Be Proven Beyond A Reasonable Doubt

The case the High Court ruled on in 2013 involved a defendant who was convicted of possession with intent to deliver heroin. The defendant agreed to the weight of the heroin as offered into evidence by the state. In this manner, the weight of the heroin was determined by a preponderance of the evidence, not proof beyond a reasonable doubt.

Therefore, the Supreme Court ruled that it was not sufficient for the defendant to merely agree to the weight of the heroin offered by the state and as such, having failed to meet the standard of proof beyond a reasonable doubt, the consideration of the weight of the substance was wholly irrelevant to the case and sentencing guidelines. In other words, the mandatory minimum sentence could not be augmented by the weight determination because the weight determination had not been proven beyond a reasonable doubt.

Why This Is Important For Defendants

These rulings set a legal precedence for the standard that critical factual issues relating to a mandatory minimum or maximum sentence must be submitted to a jury for consideration. In such scenarios, the judge is not the proper authority to impose a mandatory sentence based on evidence wherein the facts that underly consideration of the mandatory minimum or maximum must be proved beyond a reasonable doubt. It is critical in such cases that any and all factors that rely upon such an evaluation in sentencing be submitted to review by a jury.

For more information and a free consultation about any legal challenges you may be facing please contact our team at DRK Attorneys today. All of the criminal defense attorneys at DRK Lawyers are former assistant district attorneys. We use our trial experience and knowledge of the government’s tactics to help defend our clients every day in the state of Pennsylvania.