More holiday season state Blakely rulings
As noted before, with all the major Blakely rulings early this month (some details here), I thought the holiday weeks might be quiet on the Blakely front. But, as detailed here and here, just the first few days last week brought more than a dozen state and federal appellate cases dealing with Blakely issues.
In addition to the previously noted rulings here, a few more state Blakely decisions from last week recently came on-line with Patrick v. State, 2004 WL 2965848 (Ind. App. Dec. 23, 2004) (which is discussed at length here by Michael Ausbrook at INCourts) and also State v. Whatley, 2004 WL 2964710 (Tenn. Crim. App. Dec. 22, 2004). And today from the west coast today came State v. Clarke, 2004 WL 2980283 (Wash. App. Div. 1, Dec. 27, 2004) and People v. Brooks, 2004 WL 2980298 (Cal. App. 2 Dist., Dec. 27, 2004)