State v. Brown, 212 Ariz. 225

Summary

The Arizona Supreme Court held that the Sixth Amendment requires aggravating factors necessary to impose a sentence beyond the applicable presumptive term to be submitted to a jury and proved beyond a reasonable doubt, unless the defendant knowingly, voluntarily, and intelligently waives that right. The court further held that statements made during McMullen’s plea colloquy did not constitute a waiver or necessarily establish the alleged aggravating factors, and it remanded for further proceedings.

Holdings

1. A guilty plea that expressly waives jury trial on the charged offense does not, without more, waive the defendant's right to a jury trial on sentencing aggravating factors.
2. A defendant's statements during a plea colloquy do not eliminate the Sixth Amendment right to a jury determination of aggravating factors unless the guilty plea necessarily establishes those factors as elements of the offense or the defendant appropriately waives the jury right as to them.
3. McMullen retained the right to a jury trial on the alleged aggravating factors before an aggravated sentence could be imposed.

Questions Presented

1. Whether McMullen's guilty plea to reckless manslaughter implicitly waived his Sixth Amendment right to a jury trial on sentencing aggravating factors.
2. Whether McMullen's factual statements during the plea colloquy constituted admissions that permitted a sentencing judge to impose an aggravated sentence without jury findings.
3. Whether McMullen was entitled to a jury determination of the alleged aggravating factors before an aggravated sentence could be imposed.

Disposition

reversed_and_remanded