Crayton v. United States, No. 13-3548 (7th Cir. 2015)
Annotate this CaseIn Apprendi, the Supreme Court held that facts increasing a defendant’s maximum permissible sentence must be determined, beyond a reasonable doubt, by the trier of fact. In 2002, in Harris, the Court held that facts increasing the minimum permissible sentence may be found by a judge on the preponderance of the evidence. In 2013, in Alleyne, the Court overruled Harris and held that facts controlling both minimum and maximum sentences are in the jury’s province and covered by the reasonable-doubt standard. A jury convicted Crayton of distributing heroin. The indictment alleged that Hedges died from using Crayton’s product, but the jury could not decide unanimously whether Hedges’s death resulted from Crayton’s heroin. The judge found that it did. Under 21 U.S.C. 841(b)(1)(C) this required a sentence of at least 20 years’ imprisonment; without of the finding that Crayton’s heroin killed Hedges, the range would have been 0 to 20 years. The Seventh Circuit affirmed in 2011. While Alleyne’s case was pending, Crayton filed a petition under 28 U.S.C. 2255. The district court dismissed while waiting for Alleyne. When Crayton filed another after the Supreme Court issued its decision, the district court held, and the Seventh Circuit affirmed, that Alleyne does not apply retroactively on collateral review.
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