Wool and Don Stemen
"The Supreme Court sent the criminal justice systems in perhaps half of the states, and the federal system, into a state of simmering unrest. Blakely v. Washington cast doubt on two decades of efforts to channel judicial discretion in sentencing by finding that the Sixth Amendment forbids a judge to increase a criminal sentence based on facts not found by a jury beyond a reasonable doubt, even when those sentences are well short of statutory maximums."