Mandatory minimum life sentence on judge-found facts of prior convictions does not violate Apprendi

SENTENCING United States v. Holyfield, No. 05-1318, ___ F.3d ___ (10th Cir. Apr. 3, 2007)(Colorado). Appeal of sentence for conspiracy to distribute cocaine in violation of 21 U.S.C. § 841(b)(1)(A). HELD: Where statutory sentencing range is ten years to life, and defendant’s two prior convictions require mandatory minimum sentence be equal to statutory maximum (i.e., life in prison), sentence does not exceed statutory maximum. Because sentence does not exceed statutory maximum, Sixth Amendment jury trial rule of Apprendi v. New Jersey, 530 U.S. 466 (2000), does not apply. Therefore, judge-found facts of prior convictions are sufficient to support sentence. Read the opinion here.