Apprendi v. New Jersey
Historical basis

Justice Thomas explained how the original understanding of the jury-trial requirement supported the Court's ruling. He also argued that the jury-trial requirement applied to both mandatory minimum sentences and the findings of prior convictions used to enhance sentences. To make this argument, Justice Thomas had to repudiate his prior support for the prior conviction exception crafted in Almendarez-Torres v. United States, 523 U.S. 224 (1998). "What matters is the way by which a fact enters into the sentence." Even though a prior conviction may be valid because it entailed its own jury trial, the fact that that prior conviction was being used to enhance a new sentence meant that that fact must be submitted to a jury again.
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