Commonwealth, Aplt. v. Wolfe, M.

The United States Supreme Court in Alleyne v. United States1 specified that, to satisfy the jury trial right in the Sixth Amendment to the United States Constitution, any fact that triggers a mandatory minimum sentence must be (1) stated in the information; (2) an element of the offense; (3) found by a jury; and (4) found beyond a reasonable doubt. Here, the fact that triggered the imposition of Appellee Matthew Wolfe’s mandatory minimum sentence — that the victim was under the age of 16 — was (1) stated in the information; (2) an element of the offense; (3) found by a jury; and (4) found…