The U.S. Supreme Court denied certiorari this morning in Washington v. VanDelft, No. 06-1081, regarding the application of the Apprendi-Blakely line of cases to consecutive sentencing. The orders list is here. The certiorari petition is available here via SCOTUSblog.

Meanwhile, on the opposite coast, the California Supreme Court hears oral argument in People v. Sandoval, S148917. In People v. Black, 113 P.3d 534 (2005), Cal. Supreme had rejected the proposition that Blakely impacts consecutive sentencing in California. Although not squarely within the question presented (which is just how to cope with Cunningham on the upper term issue), Sandoval maintains that Cunningham requires reexamination of that aspect of Black as well. CJLF's brief is here. The consecutive sentencing discussion is on brief pages 10-14, pdf file pages 20-24.