State v. Watson
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The Supreme Court affirmed the judgment of the appellate court affirming Defendant's convictions of three distinct crimes in connection with his attack on a single victim over the course of an eight-hour period on a single day, holding that there was no error.
Defendant was convicted of assault in the third degree, unlawful restraint in the first degree, and strangulation in the second degree. On appeal, Defendant argued that his constitutional right to a jury trial was violated when the trial court, rather than the jury, determined that the charges of assault and unlawful restraint were not "upon the same incident" as that giving rise to the charge of strangulation. The appellate court affirmed. The Supreme Court affirmed, holding that the trial court's determination at sentencing that the offenses of strangulation, assault, and unlawful restraint were not "upon the same incident" did not implicate the constitutional principles underlying Apprendi v. New Jersey, 530 U.S. 490 (2000), or double jeopardy concerns.
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