Since 2000, the U.S. Supreme Court has raised serious doubts about the constitutionality of many state sentencing guidelines, holding that other than a prior conviction, any fact that increases the penalty for a crime beyond the statutory maximum must be tried before a jury (Apprendi v. New Jersey, 2000). Based on this reasoning, in 2004 the Court struck down sentencing guidelines in the State of Washington, holding that the Sixth Amendment gives juries (and not judges) the power to make a finding of fact beyond a reasonable doubt (Blakely v. Washington, 2004). The dissenters argued that the decision will serve only to increase judicial discretion and lead to less uniformity in sentencing, perhaps leading to increasing racial discrimination.
-Some state supreme courts held that Blakely did not apply to their state sentencing schemes until what case?

Question

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Cunningham v. California was a Supreme Court case that held that California's sentencing scheme, which allowed judges to impose upper term sentences based on facts not found by a jury, violated a defendant's Sixth Amendment right to a jury trial. This decision extended the holding of Blakely to state sentencing schemes and clarified that the rule applied to any state that allowed judicial fact-finding to increase a defendant's sentence beyond the maximum authorized by a jury verdict or plea. Therefore, prior to Cunningham, some state supreme courts held that Blakely did not apply to their state sentencing schemes.