United States v. Cotton

In United States v. Cotton, 535 U.S. 625 (2002), the Court restated its Apprendi holding. It then applied a plain error analysis to a conviction, and the sentence imposed incident to that conviction, where the indictment had failed to include drug quantity, where drug quantity increased the applicable maximum sentence, and defendants had made no objection at trial. The Court held that the error did not seriously affect the "fairness, integrity, or public reputation of judicial proceedings," where the pertinent evidence was "overwhelming" and "essentially uncontroverted." Thus, the convictions and sentences were upheld.