Mountjoy v. Colorado

Christopher Mountjoy was convicted of reckless manslaughter, illegal discharge of a firearm, and tampering with physical evidence after he shot and killed V.M. outside of a motorcycle clubhouse. During sentencing, the trial court found that each crime involved extraordinary aggravating circumstances. As a result, the trial court doubled the statutory presumptive maximum of each sentence. Mountjoy appealed, arguing his sentences violated his constitutional rights to due process and trial by jury under Apprendi v. New Jersey, 530 U.S. 466 (2000), and Blakely v. Washington, 542 U.S. 296 (2004). The court of appeals avoided the question of whether Apprendi and Blakely had been satisfied and concluded that, even assuming they were not satisfied, any error was harmless. The Colorado Supreme Court affirmed on different grounds: the trial court did not deny Mountjoy his rights to due process and trial by jury when it relied on facts found by the jury beyond a reasonable doubt on charges related to the offenses for which the aggravated sentences were imposed. View "Mountjoy v. Colorado" on Justia Law