United States v. Barnes, No. 11-1093 (1st Cir. 2014)
Annotate this CaseDefendant pled guilty under a plea agreement to conspiring to distribute at least fifty kilograms of marijuana and to distributing or aiding and abetting the distribution of marijuana. A judge with the First Circuit used a preponderance standard in finding facts that increased Defendant’s mandatory-minimum sentence, ultimately sentencing Barnes to 210 months’ imprisonment and five years’ supervised release. Defendant appealed, arguing that drug quantity must be treated as an element of the offense and thus proved beyond a reasonable doubt. The First Circuit affirmed based on controlling caselaw. After Defendant sought certiorari, the Supreme Court held in Alleyne v. United States that most facts that increase statutory minimum penalties must be proved beyond a reasonable doubt. The Supreme Court then granted certiorari, vacated the judgment, and remanded for further consideration in light of Alleyne. The First Circuit vacated Defendant’s sentence and remanded for resentencing, holding that the Alleyne error in this case was not harmless beyond a reasonable doubt.
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