Mizrahi v. United States

Brief for Amici Curiae Washington Legal Foundation, Due Process Institute, National Association of Criminal Defense Lawyers, and National Association for Public Defense in Support of Petitioner

Mizrahi v. United States

Brief Details
Key Topics in the Brief

Briefs

Petitioner asks this Court to resolve an important and recurring question of criminal law: whether the Sixth Amendment forbids courts from imposing forfeiture based on their own factual findings. Under our Constitution, and within the Anglo- American legal tradition generally, the right to a trial by a jury is the cornerstone of criminal adjudication. As long as there has been criminal justice in America, the independence of citizen jurors has been understood to be an indispensable structural check on executive, legislative, and judicial power. Recognizing that rich and important history, this Court held more than a quarter-century ago that the Sixth Amendment requires juries—not judges—to find all facts necessary to impose punishment. Apprendi v. New Jersey, 530 U.S. 466, 490 (2000). The Court has since applied Apprendi to all manner of criminal penalties requiring factual determinations, from fines and probation revocations to mandatory minimums and death sentences. Criminal forfeiture, too, is a punishment that can be imposed only upon a specific factual finding—that the property in question was tainted by the offense. Consistent with Apprendi and our broader legal tradition, only a jury can decide whether forfeiture is warranted.

Author(s)

Cory L. Andrews, Washington Legal Foundation, Washington, DC; William E. Havemann, Kristina Alekseyeva, Natalie Nogueira, Samantha K. Ilagan, and Jonathan Wampler, Milbank LLP, Washington, DC; Jeffrey T. Green, NACDL, Washington, DC; Shana-Tara O’Toole, Due Process Institute, Washington, DC; Emily Hughes and H. Louis Sirkin, National Association For Public Defense, Iowa City, IA

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