New York Court of Appeals
The People of the State of New York, Respondent v. Jose Leon, Appellant
February 19, 200810 N.Y.3d 122
Summary
The New York Court of Appeals affirmed the Appellate Division's sentencing order, holding that Crawford v. Washington does not apply to predicate sentencing hearings and that Apprendi v. New Jersey does not require proof beyond a reasonable doubt of the identity of prior convictions. The court reasoned that sentencing proceedings are not trial prosecutions and that the statutory scheme permits admission of fingerprint comparison reports without the full suite of trial constitutional protections.