Apprendi Doctrine Doesn’t Apply To Facts That Increase Amount of Fine

The jury-trial rule from Apprendi v. New Jersey, 530 U.S. 466 (2000), does not apply to factual findings that increase the amount of a defendant’s criminal fine, the U.S. Court of Appeals for the First Circuit held Dec. 22 (United States v. Southern Union Co.).

A decade after the landmark decision in Apprendi, questions remain whether the Sixth Amendment provides a right to have a jury find the facts underlying the imposition of a fine. “The Apprendi issue is close but the Supreme Court’s recent decision in Oregon v. Ice, [555 U.S. 160, 77 ...