United States v. CTH, No. 10-1487 (6th Cir. 2012)
Annotate this CaseDefendant pled guilty to an act of juvenile delinquency, 18 U.S.C. 5032, for possession of heroin with intent to distribute. He was 16 years old when arrested. The district court found by a preponderance of the evidence that he was responsible for distribution of 647 grams of heroin and sentenced him to five years’ official detention. The Sixth Circuit vacated and remanded. The maximum period of a juvenile’s official detention is the lesser of five years or “the maximum of the guideline range ... applicable to an otherwise similarly situated adult.” The district court’s finding that defendant was responsible for 647 grams of heroin raised his maximum period of detention so that the district court was required to make the drug-quantity finding beyond a reasonable doubt. Applying the “Apprendi” holding, the court stated that any fact that increases the penalty for a crime beyond the prescribed statutory maximum” is treated as an element of the crime itself, rather than as a sentencing factor. Juveniles, like adults, are constitutionally entitled to proof beyond a reasonable doubt when charged with violation of a criminal law.
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