Teodoro Chavez-Fernandez v. United States

“[F]act[s] that increase[] the penalty for a crime beyond the prescribed statutory maximum”—that is, all facts except for prior convictions—“must be submitted to a jury, and proved beyond a reasonable doubt.” Apprendi v. New Jersey, 530 U.S. 466, 488–90 & n.15 (2000). Apprendi grounded the rule in history and tradition but relied on precedent—Almendarez-Torres v. United States—for the exception. See id. at 477– 83, 487–90 (citing Almendarez-Torres v. United States, 523 U.S. 224 (1998)). Can Almendarez-Torres be reconciled with the Sixth Amendment’s history and tradition; and if not, should this Court overrule it?