In this month’s column, we report on two recent decisions by the United States Court of Appeals for the Second Circuit, in which the Court addressed the issue of sentencing in light of Apprendi v. New Jersey.[1] In each of the recent decisions, both of which arose under 21 U.S.C. �841, the Second Circuit extended Apprendi in important respects and underscored the confusion that surrounds sentencing determinations in the wake of Apprendi.

‘Apprendi’ Facts