Jones v. United States

In Jones v. United States, 526 U.S. 227 (1999), the Court addressed the issue of whether the sentence of a criminal defendant, charged under a federal carjacking statute, could be enhanced by the trial judge where the judge found by a preponderance of the evidence that an element of the crime had been satisfied when that element had neither been alleged in the indictment nor submitted to the jury. Jones, 526 U.S. at 229-31. The defendant in Jones was convicted by a jury of carjacking, which, under the applicable statute, carried a fifteen year sentence. Jones, 526 U.S. at 230-31. The same statute provided that the sentence was to be increased to twenty-five years if it was determined that serious bodily injury resulted from the defendant's criminal acts. Jones, 526 U.S. at 230. The jury made no finding regarding the element of serious bodily injury, which had not been alleged in the indictment. Jones, 526 U.S. at 230-31. However, during sentencing the trial judge treated the serious bodily injury element as a sentencing factor and found by a preponderance of the evidence that the defendant had caused serious bodily injury; he therefore increased defendant's sentence from fifteen to twenty-five years. Jones, 526 U.S. at 231. The Court held that the trial judge had erred and that under the statute at issue the serious bodily injury element must be alleged in the indictment and determined by a jury beyond a reasonable doubt. Jones, 526 U.S. at 251-52. In Jones, the United States Supreme Court was interpreting the federal carjacking statute, 18 U.S.C. 2119 (1993), which provides for three levels of punishment depending on whether the victim was uninjured or slightly injured, seriously injured, or killed during the carjacking. According to the majority, this statute could be interpreted as one offense with three possible penalties or three separate offenses. The Court held: "Under the Due Process Clause of the Fifth Amendment and the notice and jury trial guarantees of the Sixth Amendment, any fact (other than prior conviction) that increases the maximum penalty for a crime must be charged in an indictment, submitted to a jury, and proven beyond a reasonable doubt." Jones, 526 U.S. at 243. To prevent trial courts from imposing a greater punishment without charging all of the essential elements in the indictment, the Court held the statute created three separate offenses that must be charged from the outset. Jones, 526 U.S. at 252. The Supreme Court overturned the defendant's carjacking conviction under 18 U.S.C. 2119 (1998) in which an enhanced sentence had been imposed because the trial court found the victim had sustained serious bodily injury. Noting that the basic carjacking statute was incomplete without one of the three sub-sections defining the appropriate penalty, the Court concluded that the serious bodily injury factor was a substantive element of an offense other than the one charged in the indictment. Therefore, it held that the statute must be read as defining three separate offenses, rather than a single offense with two sentence-enhancing circumstances. The Jones court relied in part on its observation that in federal criminal prosecutions, sentence-enhancing circumstances are determined by a preponderance of the evidence by the trial court, not by the jury, without notice to the defendant in the indictment.