Summary of Argument

This case involves an issue of extraordinary importance to the lives of vulnerable youth – whether New Mexico’s amenability hearing structure unconstitutionally denies juveniles the right to have a jury decide whether they may receive an adult sentence.

New Mexico’s sentencing structure provides that a child can face an adult criminal sentence after appearing and participating in only juvenile proceedings. In order to impose an adult sentence, the judge must find that the child is “not amenable to treatment or rehabilitation as a child in available facilities” and that the child “is not eligible for commitment to an institution for children with developmental disabilities or mental disorders.” § 32A-2-20(B). The consequences to these children are profound. Rudy’s maximum sentence as a juvenile would have been confinement until age twenty-one – approximately three-and-a-half years. See § 32A-2-19(B)(1). Instead, he was subject to, and received, a twenty-five-year sentence.

The U.S. Supreme Court has long held that the judiciary must vigilantly guard against trial practices that reduce the jury’s significance, and that the jury right is of “surpassing importance.” Apprendi v. New Jersey, 530 U.S. 466, 476 (2000). See also Jones v. United States, 526 U.S. 227 (1999). In Apprendi v. New Jersey, the United States Supreme Court determined that a bright-line rule that a defendant is entitled to trial by jury beyond a reasonable doubt for any fact, other than the existence of a prior conviction, that increases a defendant’s sentence beyond the statutory maximum, would best protect this right. See 530 U.S. at 490.

In New Mexico v. Gonzales, 2001-NMCA-025, 130 N.M. 341, 24 P.3d 776, the New Mexico Court of Appeals held that section 32A-2-20 does not violate Apprendi because the amenability determination differs from findings related to elements of the crime. Id. ¶¶ 24, 26. Gonzales also set forth that Apprendi did not apply because all of the sentences were within the statutory range. Id. ¶ 31. As the Court of Appeals recognized in the proceedings below, subsequent United States Supreme Court cases rejected the reasoning supporting Gonzales. Rudy B., 2009-NMCA-104, ¶¶ 34-54.

Specifically, after the Court of Appeals decided Gonzales, the Supreme Court clarified that Apprendi applies to fact-finding in a variety of contexts, including sentencing factors like those at issue here. Ring v. Arizona, 536 U.S. 584 (2002); Blakely v. Washington, 542 U.S. 296 (2004); Cunningham v. California, 549 U.S. 270 (2007). The Court also specified that a statutory maximum is the maximum sentence a judge could impose based on the facts considered by the jury. Ring, 536 U.S. at 602. The other sentencing schemes to which the Court applied Apprendi, amenability hearings require judicial fact-finding as a prerequisite to increasing the defendant’s sentence above the statutory maximum.

The Court of Appeals thus properly overruled Gonzales and held that section 32A-2-20(B) and (C) defied Apprendi’s bright-line rule, and, therefore unconstitutionally eroded the Sixth Amendment right to trial by jury. Id. Amici respectfully request this Court to affirm that judgment.

Summary of Argument

This case focuses on the constitutionality of New Mexico's amenability hearing structure, specifically addressing whether it violates the right to a jury trial for juveniles facing adult sentencing.

New Mexico's sentencing framework permits the imposition of adult criminal sentences on juveniles following juvenile proceedings. To justify such a sentence, a judge must determine that the child is unsuitable for juvenile rehabilitation and ineligible for placement in a developmental disability or mental disorder facility. This structure can lead to significant disparities in sentencing, as illustrated by Rudy's case, where he received a twenty-five-year adult sentence despite facing a maximum juvenile sentence of three-and-a-half years.

The U.S. Supreme Court has consistently emphasized the paramount importance of the right to a jury trial, particularly in protecting against practices that diminish the jury's role. The landmark case of Apprendi v. New Jersey established a clear rule: any fact that increases a defendant's sentence beyond the statutory maximum, except for prior convictions, must be determined by a jury beyond a reasonable doubt.

The New Mexico Court of Appeals, in New Mexico v. Gonzales, initially ruled that Apprendi did not apply to amenability hearings, arguing that such hearings focus on rehabilitation rather than elements of the crime. However, subsequent Supreme Court rulings, including Ring v. Arizona, Blakely v. Washington, and Cunningham v. California, extended Apprendi's reach to encompass sentencing factors, including those relevant to amenability. These rulings also clarified that the statutory maximum refers to the maximum sentence a judge can impose based on the jury's findings.

The Court of Appeals, recognizing the implications of the later Supreme Court decisions, overruled Gonzales and determined that New Mexico's amenability hearing structure conflicts with Apprendi’s bright-line rule, effectively undermining the Sixth Amendment right to a jury trial. This argument underscores the need for a judicial determination that affirms the Court of Appeals' decision.

Summary of Argument

This case addresses the constitutionality of New Mexico’s amenability hearing structure, which determines whether a juvenile can be sentenced as an adult. The issue at hand is whether the current system, which allows a judge to determine an adult sentence without a jury trial, violates the Sixth Amendment right to a jury trial.

New Mexico’s sentencing structure permits juveniles to receive adult criminal sentences following only juvenile proceedings. To impose an adult sentence, the judge must conclude that the child is not amenable to treatment or rehabilitation in juvenile facilities. The consequences for these juveniles can be significant. For example, in this case, the juvenile’s maximum sentence as a juvenile would have been confinement until age twenty-one. Instead, the juvenile received a twenty-five-year sentence.

The Supreme Court has established that the jury right is a cornerstone of the justice system and must be carefully protected. In Apprendi v. New Jersey, the Court ruled that any fact that increases a defendant’s sentence beyond the statutory maximum must be determined by a jury beyond a reasonable doubt. This ruling protects the jury’s role in determining the severity of a sentence.

The New Mexico Court of Appeals initially upheld the amenability hearing structure in New Mexico v. Gonzales, arguing that the Apprendi rule did not apply to these proceedings. However, subsequent Supreme Court decisions clarified that Apprendi applies to fact-finding in sentencing, including amenability determinations. These decisions emphasize that the statutory maximum sentence is the maximum a judge can impose based on the jury’s findings.

The Court of Appeals properly overturned Gonzales, recognizing that New Mexico's amenability hearing structure violates Apprendi. The Amici urge the Court to affirm this judgment, upholding the Sixth Amendment right to a jury trial and ensuring that the jury’s role in determining the severity of a sentence is preserved.

Summary of Argument

This case involves whether New Mexico's law that lets a judge decide if a juvenile can be sentenced as an adult is unconstitutional. The law allows for a judge to decide if a juvenile is "amenable to treatment" and if they can be sent to a juvenile facility, or if they should be sentenced as an adult.

The state of New Mexico argues that this law does not violate the Sixth Amendment right to a jury trial, because it does not relate to the actual crimes committed. The U.S. Supreme Court has ruled that juries must decide all facts that increase a defendant's sentence beyond the statutory maximum.

The New Mexico Court of Appeals found that the state's law does violate the Sixth Amendment because the judge's decision to sentence a juvenile as an adult is a fact that increases their potential sentence beyond the maximum that a juvenile would receive.

This case has implications for the rights of vulnerable youth, as the law could mean they are deprived of the right to a jury trial and face longer sentences as a result of a judge's decision.

Summary of Argument

This case is about whether a law in New Mexico is fair to kids. The law says that a judge can decide if a kid should be treated like an adult in court, even if the kid is still young.

This law means that a kid could get a long sentence as an adult, even though they’re still a child. This could mean that they get locked up for a much longer time than they would if they were treated like a child in court.

The U.S. Supreme Court has said that the right to have a jury decide how long someone goes to jail is very important. But in New Mexico, the judge gets to decide how long a kid goes to jail without a jury.

The Supreme Court has said that this kind of law is unfair because it takes away the right of the kid to have a jury decide their sentence. This case is about whether the Supreme Court should say that this New Mexico law is unfair.