Apprendi v. New Jersey

Summary

Hate crime law, which provides for sentence enhancement based on proof by a preponderance of the evidence, is constitutional.



        The N.J. Supreme Court upheld the constitutionality of a state hate crime law, which extended the sentence of a defendant based on proof by a preponderance of the evidence, rather than proof beyond a reasonable doubt.

        
Charles Apprendi was arrested for shooting into his neighbor's house. Apprendi admitted that he fired rifle shots into the home because its residents were black, and he did not what them in the neighborhood. Apprendi pleaded guilty to possession of a firearm for an unlawful purpose, and to unlawful possession of a prohibited weapon. In sentencing, the trial court concluded that Apprendi's actions were a product of racial bias, thereby triggering a New Jersey hate crime law that enhanced sentencing for crimes with a bias purpose. As a result, the court extended Apprendi's sentence. The appellate court affirmed. Apprendi argued that the New Jersey statute unconstitutionally allowed the imposition of an extended sentence term based on proof of the bias by a preponderance of evidence, rather than proof beyond a reasonable doubt.

        
The N.J. Supreme Court affirmed. The use of the preponderance of the evidence standard to determine whether an extended sentence should be mandated did not violate the constitutional requirement that a state must prove each element of a crime beyond a reasonable doubt. A court taking into account a biased purpose in determining sentencing is similar to taking into account factors such as recidivism. The consideration of a biased purpose does not create a separate crime or element of a crime.

—