http://www.vera.org/publication_pdf/250_477.pdf?bulletin=33&token=1262
Jon Wool
"Few Supreme Court decisions have engendered as much uncertainty in state and federal courts as Blakely v. Washington. This report, the second in a series on the practical implications of the ruling, examines the legal issues raised by Blakely and prior related decisions. The Court ruled in June that any factor that increases a criminal sentence above an established threshold must be proved to a jury beyond a reasonable doubt (or admitted by the defendant) and cannot be imposed by a judge alone. The ruling cast doubt on two decades of sentencing reform efforts."
