The following excerpt is from United States v. Gowing, Docket No. 10-4073-cr(L), Docket No. 11-683-cr (Con) (2nd Cir. 2012):
that based on the jury questions, the jury might have found that he continued to commit the conspiracy only during this window, which (he argues) was not a period of "release[]." Thus, according to Gowing, the jury charge violates the rule of Apprendi v. New Jersey, 530 U.S. 466 (2000).
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