United States v. Payne

Defendant appealed his sentence after pleading guilty to one count of bank robbery. Defendant argued that the district court violated his Sixth Amendment rights, as interpreted by Alleyne v. United States, when it sentenced him to the mandatory minimum sentence on the firearm charge. The court concluded that the district court erred under Alleyne because it sentenced defendant to a mandatory minimum sentence based on its own conclusion about brandishing, instead of defendant's admission or a jury's finding concerning that fact. Nevertheless, the error was harmless beyond a reasonable doubt. Accordingly, the court affirmed the judgment of the district court.View "United States v. Payne" on Justia Law