Blakely v. Washington

542 U.S. 296 (2004)

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Nature of the Case

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Facts

Blakely (D) abducted his estranged wife from their home binding her with duct tape and forcing her at knifepoint into a wooden box in the bed of his pickup truck. In the process, he implored her to dismiss the divorce suit and related trust proceedings. Their son was ordered by D to get in a car, or his mother would be harmed. The boy escaped at a gas station, and D was apprehended. D was charged with first-degree kidnapping. By plea agreement, it was reduced to second-degree kidnapping involving domestic violence and use of a firearm. P entered a guilty plea admitting the elements of second-degree kidnapping and the domestic-violence and firearm allegations, but no other relevant facts. State law was clear on the sentencing requirements. A judge had the power to impose a sentence above the standard range if she finds 'substantial and compelling reasons justifying an exceptional sentence.' When a judge imposes an exceptional sentence, she must set forth findings of fact and conclusions of law supporting it. The State recommended a sentence within the standard range of 49 to 53 months. After hearing the facts, the judge rejected the State's recommendation and imposed an exceptional sentence of 90 months--37 months beyond the standard maximum: D had acted with 'deliberate cruelty,' a statutorily enumerated ground for departure in domestic-violence cases. D objected. The judge accordingly conducted a 3-day bench hearing featuring testimony from D, Yolanda, Ralphy, a police officer, and medical experts. Thirty-two findings of fact were made. The judge adhered to his initial determination of deliberate cruelty. D appealed. The State Court of Appeals affirmed. The Washington Supreme Court denied discretionary review. The Supreme Court granted certiorari.