Jones V. United States (1999) - Facts

Facts

Jones and two accomplices, Oliver and McMillan, held up two men, Mutanna and Mardaie. Jones and McMillan took the victims' money. Oliver beat Mutanna with a gun. Olver and McMillan left the scene in Jones's car, while Jones forced Mardaie into Mutanna's car and drove off in it. Jones stopped to put Mardaie out, then sped off again, chased this time by the police. Jones then crashed into a telephone pole, ending the chase.

Jones was indicted in the United States District Court for the Eastern District of California for violating the federal carjacking statute, 18 U.S.C. § 2119. The indictment did not name the particular subsection Jones was accused of violating. The magistrate judge informed Jones he faced a maximum sentence of 15 years, the smallest maximum sentence under the statute's three subsections. The trial judge instructed the jury under that subsection, which did not require proof of the fact or the extent of the victim's injuries. Jones was convicted of the carjacking count. A presentence investigation report recommended that Jones receive a 25-year sentence because one of the victims had suffered "serious bodily injury". Jones objected that this sentence was not authorized because the serious bodily injury component was not charged in the indictment. The district court overruled this objection, found that there had been serious bodily injury by a preponderance of the evidence, and imposed a 25-year sentence. On appeal, the Ninth Circuit took the view that the enhanced provisions were merely sentencing factors that did not need to be set forth in the indictment or submitted to the jury. It therefore affirmed this aspect of Jones's conviction. The U.S. Supreme Court then agreed to review the case.