Lilron Ravon Jones v. California
DueProcess
Whether it is constitutionally permissible to use a prior juvenile adjudication to enhance a sentence regardless of whether the juvenile had a right to a jury trial in that prior proceeding?
Question Presented In Apprendi v. New Jersey, 530 U.S. 466, 490 (2000), this Court held that “[o]ther than the fact of a prior conviction, any fact that increases the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury, and proved beyond a reasonable doubt.” This case concerns the application of Apprend/ to non-jury juvenile adjudications. California courts here have held that petitioner’s juvenile adjudication fell within Apprendi'’s prior conviction exception and hence could be used to enhance his sentence for a subsequent criminal conviction without being proved to ajury. That decision implicates an important and recurring constitutional question, which has split federal and state courts of appeal. The importance of resolution of this conflict is particularly great in light of this Court’s decisions in in Descamps and Mathis. Under those cases, a fact cannot be used to enhance a sentence unless it is found true by a jury (as an element of the prior charge). This narrowed the reading of the prior conviction exception to Apprendi and underscored that the right to a jury trial is an indispensable procedural protection, i without which the prior cannot be used for enhancement purposes. Descamps and Mathis counsel in favor of not allowing the use of prior juvenile adjudications to enhance a current adult sentence if the right to a jury trial was not available in the prior juvenile adjudication proceeding. And the question presented is whether it is constitutionally permissible to use a prior juvenile adjudication to enhance a sentence regardless of whether the juvenile had a right to a jury trial in that prior proceeding? il