State v. Reimer
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The Supreme Court affirmed the judgment of the court of appeals concluding that a Blakely violation committed by the district court at a sentencing hearing was harmless beyond a reasonable doubt, holding that the Blakely violation was harmless beyond a reasonable doubt.
After a jury trial, Defendant was found guilty to two counts of criminal sexual conduct. The complaint alleged that the offenses were committed sometime between 2004 and 2018, but at sentencing, the district court determined that Defendant's offenses were committed after August 1, 2006. The court of appeals affirmed Defendant's sentence, concluding (1) the lower court's determination of Defendant's offense dates was a violation of Blakely v. Washington, 542 U.S. 196 (2004), and its progeny; but (2) the error was harmless. The Supreme Court affirmed, holding that although the district court erred in determining that date of Defendant's offense without receiving a Blakely waiver from Defendant, but the error was harmless beyond a reasonable doubt.
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