People v. Prindle

The Court of Appeals upheld the constitutionality of New York’s discretionary persistent felony offender sentencing scheme, holding that, in light of Alleyne v. United States, 570 U.S. __ (2013), this sentencing scheme does not violate Apprendi v. New Jersey, 530 U.S. 466 (2000), nor does it violate Defendant’s due process and Sixth Amendment rights. Defendant argued New York’s persistent felony offender statute, N.Y. Penal Law 70.10(1)(a), increased the sentencing floor for persistent felony offenders. The Court of Appeals held that even if Defendant was correct in his characterization, the increase to the sentencing floor would not be the result of impermissible judicial fact-finding. The court further held that the statute falls squarely within the exception afforded by Almendarez-Torres v. United States, 523 U.S. 224 (1998), because it exposes defendants to an enhanced sentencing range based only on the existence of two prior felony convictions. View "People v. Prindle" on Justia Law