In the case of Ralph Howard Blakely, Jr. v. Washington in 2003, the U.S Supreme Court ruled that sentencing guidelines which allow judges to increase a defendant's sentence based on facts not presented to a jury or admitted by the defendant are unconstitutional. The court held that this violated the Sixth Amendment right to trial by jury as it allowed judicial discretion beyond statutory maximums set for specific crimes without requiring proof beyond reasonable doubt. This decision was significant because it challenged many states' sentencing laws and led to changes in federal sentencing procedures.

In the dissenting opinion for Ralph Howard Blakely, Jr. v. Washington, Justice Sandra Day O'Connor expressed concern that the majority's decision would have a significant impact on sentencing reform efforts across the country and could potentially undermine decades of progress in this area. She argued that judges should be allowed to consider all relevant facts when determining sentences, including those not specifically mentioned in a defendant's indictment or proven beyond a reasonable doubt at trial. This approach, she believed, helped ensure fairer and more consistent sentences by allowing judges to take into account each individual defendant’s circumstances rather than relying solely on rigid statutory guidelines. Furthermore, she disagreed with the majority's interpretation of Apprendi v New Jersey (2000), asserting it was never intended to apply so broadly as to restrict judicial discretion in sentencing decisions within statutory limits.