Arizona Supreme Court addresses "admissions" for Apprendi/Blakely purposes

Proving yet again that state courts often give more attention and respect to Blakely issues than their federal counterparts, the Arizona Supreme Court late last week issued a thoughtful and thorough opinion on Blakely "admissions" in State v. Brown/McMullen, No. CV-05-0263-PR (Ariz. Mar. 16, 2006) (available here).  Though arising through a procedurally complicated setting, the issue and the court's unanimous ruling are clear:

The issue in this case is whether a defendant's statements during a plea colloquy relieve the State of its obligation under Apprendi v. New Jersey, 530 U.S. 466 (2000), and its progeny to prove aggravating factors to a jury.  We conclude that the Sixth Amendment requires that "any fact that increases the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury, and proved beyond a reasonable doubt," id. at 490, unless a defendant has knowingly, voluntarily, and intelligently waived his right to jury trial with respect to aggravating factors....

In short, we hold that the Sixth Amendment right to jury trial with respect to an aggravating factor necessary to impose a sentence remains inviolate unless the defendant's plea of guilty necessarily establishes the aggravating factor (because the facts admitted are elements of an offense to which the defendant has pled guilty) or the defendant has appropriately waived his right to jury trial with respect to these aggravating factors.