Washington v. Recuenco
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In Recuenco v. Washington, 126 S. Ct. 2546 (2006), the United States Supreme Court held that harmless-error analysis applied to jury enhancements where a sentence increased based on a judge's own factual findings rather than a jury verdict. This 6-3 decision, written by Justice Clarence Thomas and joined by Antonin Scalia, limited the scope of Blakely v. Washington, 542 U.S. 296 (2004), with respect to sentence enhancements. This decision reinstated a sentence enhancement vacated by the Supreme Court of Washington.