for sentencing purposes must be established through a collateral, post-verdict adjudication at which the applicable procedural protections are significantly lower than those applicable at the trial itself. For example, a criminal defendant enjoys the right to a trial by jury, see U.S. Const, amend. VI, but that right does not exist at sentencing, see, e.g., Spaziano v. Florida, 468 U.S. 447, 459, 104 S.Ct. 3154, 3161, 82 L.Ed.2d 340 (1984). At trial, an element of a charged offense must be proven beyond a reasonable doubt, see In re Winship, 397 U.S. 358, 364, 90 S.Ct. 1068, 1072, 25 L.Ed.2d 368 (1970), but most pertinent sentencing facts need only be established by a preponderance of evidence, see McMillan v. Pennsylvania, 477 U.S. 79, 91, 106 S.Ct. 2411, 2418, 91 L.Ed.2d 67 (1986) (<HOLDING>); United States v. McDowell, 888 F.2d 285,
holding that standard for revocation of probation is preponderance of the evidence holding that the proper standard of proof is preponderance of the evidence holding that the preponderance standard is generally appropriate in guidelines sentencing holding that the preponderance standard is generally constitutional holding that the standard of proof for dischargeability actions is the preponderance of the evidence standard