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Case Facts, Law and Ruling
Alleyne was accused of carrying or using a weapon in a robbery incident. In this regard, the US constitution prohibits carrying, brandishing, or unleashing unlicensed weapons. Illegal possession of firearms attracts a jail term of not less than five years. However, the minimum sentence increases to seven years if the weapon is brandished and ten years if it is unleashed during a crime.
The trial court convicted Alleyne to seven years of imprisonment. The judge assumed that Alleyne brandished the weapon during the robbery incident. Acting in self-defense, Alleyne rejected the ruling claiming that it violated his rights in the Sixth Amendment. In this regard, the Sixth Amendment gives all accused individuals the right to a speedy and public hearing. The amendment also entitles accused people to fair representation by qualified and impartial state juries. This Amendment was established by the US Parliament to protect accused people against unfair criminal proceedings. It should be noted that the amendment only applies to crime suspects.
Alleyne claimed that minimum imprisonment could only be raised after a jury had assessed and confirmed the reasonableness of the facts that led to the increase. The accused, therefore, rejected the decision because brandishing claims were not found reasonable by the jury.
The trial court relied on a ruling in a similar case to reach its verdict (Harris v. United States, 536 U. S. 545). In Harris v. United States, it was ruled that the Sixth Amendment allowed minimum sentence to be increased depending on the prevailing case facts.
When Alleyne’s case was taken to the Supreme Court, the initial verdict was overturned. The Supreme Court also relied on a ruling in a similar case to reach its verdict (Apprendi v. New Jersey, 530 U. S. 466). In the case of Apprendi v. New Jersey, the judges used two facts to arrive at the conclusion. First, it was asserted that all facts that led to minimum sentence increase should relate to the case in question. Secondly, it was claimed that all facts that related to the case should be considered by a jury. It was, therefore, concluded that all facts that led to minimum sentence increase ought to be considered by a jury. By overturning the ruling in Alleyne v. United States, the Supreme Court also questioned the decision in Harris v. United States.
Importance of the Case
Alleyne V. United States is an important case because it reveals some gaps in the existing laws. First, without mentioning the brandishing, 7 years are justifiable because 5 is the minimum and life imprisonment is the maximum. This implies that the initial decision would have remained if the trial judge had not used brandishing claims in the ruling. In this regard, one case can lead to different outcomes depending on the terms used. Case outcomes cannot be predicted under such circumstances.
Accomplice Liability and Criminal Liability
A person cannot be declared guilty in relation to a crime if criminal liability is not established (Arafa, 2008). In this case, criminal liability only prevails if the following two conditions are met. First, it has to be established beyond reasonable doubt that the suspected person indeed has committed the crime. Secondly, it has to be established that the person has intended to commit the crime. In the case of Alleyne V. United States, the court needed to establish that Alleyne illegally carried or used a weapon to commit an act of violence. The court also needed to establish that he had the intension of carrying or using the weapon to commit violence (Arafa, 2008).
Sometimes people can be found criminally responsible for criminal acts they have never committed (Arafa, 2008). In this case, a person who assists or encourages another individual to commit a criminal act bears criminal responsibility as an accomplice. To declare that someone bears accomplice responsibility, it has to be established that the person really wanted the crime to be committed to the end. It should also be established that in addition to the target crime, the person would be guilty of any other crime that is likely to be committed in the course of committing the target crime. In the case of Alleyne V. United States, the person who supplied the weapon to Alleyne knowing that it would be used to commit a crime was an accomplice (Arafa, 2008).
In the US, there are several crime elements that need to be fulfilled for accused people to be declared guilty. The first element is mens rea – meaning state of the mind (Yeo, 2002). According to this element, accused people can only be declared guilty if they committed crimes willingly. In this regard, people cannot be criminally responsible for offenses they committed unknowingly.
The second element is actus reus – meaning criminal act (Yeo, 2002). According to this element, people can only be criminally responsible for the crimes they actually committed. The element forbids convicting a person for merely wishing to commit a crime. The third element of crime is concurrence. This element requires that both mens rea and actus reus occur together for one to be declared criminally responsible for an offense. The fourth element of crime is causation. In this case, a person can only be criminally responsible if the crime in question leads to actual harm. A person cannot be accused of homicide unless killing has been involved.
Alleyne V. United States (11-9335).
Appsrendi v. New Jersey, 530 U. S. 466.
Arafa. M. A. (2008). Criminal complicity – accomplice criminal liability to the criminal offences ‘a comparative analysis between the Egyptian criminal law system and the criminal law system of the United States of America’. Alexandria: Alexandria University.
Harris v. United States, 536 U. S. 545.
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Yeo, S. (2002) Causation, Fault and the Concurrence Principle. Otago Law Review. 10(2): 214-224.